One of the most common misunderstandings about GPSR is that selling through a marketplace (Amazon, eBay, Etsy, Zalando, ASOS Marketplace) transfers compliance responsibility to the platform. This is not correct. GPSR assigns direct obligations to economic operators — and marketplace sellers are economic operators.
What GPSR says about marketplace sellers
GPSR Article 22 ("Providers of online marketplaces") places specific duties on marketplace platforms — they must ensure product listings include certain information and must act on safety notices. However, this does not reduce the obligations on sellers themselves.
As a marketplace seller, you are classified as a distributor under GPSR (if you sell goods manufactured by others) or as a manufacturer (if you make or substantially modify products). Both classifications carry compliance obligations:
- Distributors must verify that products carry the manufacturer's name and address before placing them on the market. They must immediately report safety concerns to the manufacturer and competent authorities.
- Manufacturers must apply CE marking where required, draw up EU declarations of conformity, and maintain technical documentation.
What Amazon specifically requires
Since the GPSR deadline, Amazon has updated its seller policies to require GPSR-compliant product listings in its EU stores. Amazon now requires:
- Manufacturer name and address in the "Compliance" field of product listings
- EU Responsible Person details (for non-EU brands)
- Product safety warnings where applicable
- Safety certifications and test reports for regulated product categories
Listings that do not comply with Amazon's GPSR requirements are at risk of being suppressed. Amazon runs its own automated compliance checks and has suspended seller accounts for systematic non-compliance.
What Etsy sellers need to know
Etsy's marketplace includes many small EU sellers who may be exempt from GPSR as microenterprises. However, the microenterprise exemption requires active verification — sellers must genuinely meet the criteria (fewer than 10 employees, under €2M annual turnover) and document this.
Etsy has issued guidance to EU sellers but has been slower than Amazon to enforce compliance at the listing level. However, national enforcement authorities can still reach Etsy sellers directly — Etsy's policies do not insulate sellers from regulatory enforcement.
The EU Responsible Person requirement
If you sell products manufactured outside the EU and you are not based in the EU yourself, GPSR requires you to appoint an EU Responsible Person. This must be:
- An entity (individual or company) with a registered address within the EU
- Formally authorised in writing to act on your behalf
- Whose name and EU address appears on every product and/or product listing
Several service providers now offer EU Responsible Person services specifically for this purpose. Costs range from €50 to several hundred euros per year depending on the number of product categories.
Practical steps for marketplace sellers
- Review each product listing for manufacturer name and address
- Add or update the EU Responsible Person field in marketplace listings
- Ensure product identifiers (model numbers, batch references) are visible in listings
- For regulated product categories, verify that safety certifications are current
- If you also have your own store, scan it with EuroGPSR to identify compliance gaps
Marketplace compliance and direct store compliance go hand-in-hand. A GPSR inspection of your store often leads authorities to review your marketplace presence too.