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GPSR Enforcement in the Netherlands — How the ACM Is Auditing Online Sellers

1 May 2025 6 min readUpdated 22 April 2026

The Netherlands has one of the EU's most active product safety enforcement bodies: the Autoriteit Consument & Markt (ACM), supported by the Nederlandse Voedsel- en Warenautoriteit (NVWA) for specific product categories. Since GPSR came into force in December 2024, these authorities have conducted systematic sweeps of online marketplaces and independent ecommerce stores — with a particular focus on cross-border sellers targeting Dutch consumers.

How ACM approaches GPSR enforcement

The ACM uses a risk-based enforcement model. Their priorities in 2025 are:

  1. High-risk product categories: electrical appliances, children's toys, personal care devices, and products with chemical components
  2. Marketplace sellers: Amazon.nl, bol.com, and Coolblue listings from sellers without verified GPSR documentation
  3. Direct ecommerce stores: Stores actively advertising to Dutch consumers via Google Ads, Meta Ads, or Dutch-language SEO
  4. Repeat offenders: Sellers previously warned by German or French authorities who continue selling into the Netherlands

What the ACM specifically checks

ACM product safety inspectors examine online product listings for:

  • Manufacturer name and postal address (physical address, not just a country)
  • Electronic contact information (email or contact form)
  • Product identifier (SKU, batch number, or model reference)
  • Safety warnings in Dutch (required for Dutch-market products)
  • EU Responsible Person identification for non-EU manufactured goods
  • Accessible returns and withdrawal rights information
  • Cookie consent compliance (GDPR enforcement is coordinated with the AP, the Dutch DPA)

ACM fines and enforcement actions

Under the Dutch Consumer and Market Authority Act, the ACM can impose administrative fines up to €900,000 for serious violations or up to 1% of worldwide annual turnover. For GPSR violations, the typical enforcement sequence is:

  1. Formal warning (aanschrijving): Written notice requiring compliance within 4–8 weeks
  2. Administrative order with periodic penalty (last onder dwangsom): Fine accumulates daily until compliance
  3. Administrative fine (bestuurlijke boete): Fixed penalty for confirmed violation
  4. Product recall or market withdrawal order: For products that pose actual safety risks

In practice, the ACM has been issuing formal warnings with 6-week compliance deadlines to non-compliant online sellers. Fines issued in Q1 2025 ranged from €12,500 to €85,000 for first-time violations involving missing mandatory product information.

The bol.com compliance pressure

Bol.com — the Netherlands' dominant marketplace — has independently started enforcing GPSR on its seller platform. From January 2025, bol.com requires all product listings to include manufacturer information and product identifiers. Listings without this data are being suppressed from search results or removed outright. This marketplace pressure is driving many Dutch-market sellers to address GPSR compliance regardless of direct regulatory action.

What Dutch-market sellers must do

If you sell physical products to Dutch consumers — whether through your own store, bol.com, or Amazon.nl — you need:

  • Manufacturer name and postal address on every product page
  • A Dutch-language version of any safety warnings
  • An EU Responsible Person identified if your manufacturer is outside the EU
  • GDPR-compliant cookie consent (coordinate with your GPSR implementation — both require a compliant privacy policy)
  • Accessible contact details and a visible returns policy

Audit your store for ACM-specific requirements

EuroGPSR automatically checks Dutch-market stores for the GPSR signals most commonly cited in ACM enforcement actions. Scan your store for free — no account required — and get a severity-ranked list of issues with specific steps for your platform (Shopify, WooCommerce, PrestaShop, or custom).

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