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GPSR High-Risk Product Categories: What Ecommerce Sellers Must Know

1 July 2025 7 min readUpdated 3 May 2026

The General Product Safety Regulation (GPSR, EU 2023/988) applies to all consumer products placed on the EU market — but not all products face the same scrutiny. Certain categories attract heightened attention from market surveillance authorities because of their inherent risk profile, their history of incidents, or the presence of vulnerable user groups such as children, elderly people, or immunocompromised individuals. Understanding which categories face stricter requirements — and what those requirements are — is essential for any ecommerce seller operating in the EU.

Category 1: Electronics and electrical equipment

Electronics are among the most actively monitored product categories in the EU. Multiple regulatory frameworks overlap, creating a complex but clearly defined set of obligations:

  • CE marking: Required for most electrical products under the Low Voltage Directive (LVD, 2014/35/EU) for products operating between 50–1000V AC or 75–1500V DC, and the EMC Directive (2014/30/EU) for electromagnetic compatibility. CE marking must appear on the product and its packaging.
  • Safety information on product pages: Operating voltage and wattage, safe operating temperature range, and specific hazard warnings must be visible on the product listing in the language of the destination market. English-only warnings are non-compliant for German, French, or other non-English markets.
  • Country of origin: Required for electronics sold to EU consumers. Must appear on the product page and packaging.
  • EU Responsible Person: Practically mandatory for non-EU manufacturers. The Bundesnetzagentur in Germany has been particularly active in identifying electronics listings that lack a valid EU Responsible Person contact.

Battery products attract additional regulation under the EU Battery Regulation (EU 2023/1542), which introduces extended producer responsibility and labelling requirements for all batteries sold in the EU.

Category 2: Toys and children's products

Toys are the single most scrutinised consumer product category in EU market surveillance. The German Bundesnetzagentur specifically includes toys in its automated digital sweep programmes, and RAPEX (the EU rapid alert system) receives more toy safety notifications than any other product category.

  • Toys Safety Directive (2009/48/EC): CE marking is mandatory. Conformity assessment must be conducted before the toy is placed on the EU market.
  • Age warnings: The "not suitable for children under 3 years" warning (with the specific ISO pictogram) is mandatory on product pages and packaging where applicable.
  • Choking hazard notices: Required when the toy or any component presents a choking risk. Must appear prominently on the product page — not just in a long product description.
  • Material composition and chemical safety: The REACH Regulation (EC 1907/2006) applies strictly to toys. Substances of Very High Concern (SVHCs) must be declared if present above 0.1% by weight.
  • Language: All warnings and safety information must be in the official language of the member state where sold — a German-speaking buyer must receive German-language warnings.

Category 3: Textiles and clothing

The EU Textile Regulation (EU 1007/2011) pre-dates GPSR but continues to apply alongside it. For ecommerce sellers, the key requirements for textiles and clothing are:

  • Fibre composition label: Required in the official language(s) of the destination country. A product listing for French consumers must include the fibre composition in French.
  • Care instructions: Must be present on the product page and the physical label, using EU-standard care symbols (ISO 3758).
  • Chemical safety: The REACH Regulation applies to textiles, particularly for imported goods. Restricted substances include certain azo dyes, formaldehyde, and heavy metals. Non-EU manufacturers must provide documentation that their textiles comply with EU chemical restrictions.
  • Children's clothing: Faces additional requirements — drawstring safety standards (EN 14682) apply, and stricter chemical safety thresholds are set for garments intended for children under 14.

Category 4: Cosmetics and personal care

The EU Cosmetics Regulation (EC 1223/2009) creates a parallel compliance framework that operates alongside GPSR. For ecommerce sellers of cosmetics and personal care products, the additional requirements include:

  • Responsible Person (cosmetics-specific): The EU Cosmetics Regulation requires a Responsible Person established in the EU — separate from the GPSR Responsible Person, though sometimes the same legal entity. The cosmetics Responsible Person must notify products in the CPNP (Cosmetic Products Notification Portal) before they are placed on the market.
  • Full ingredient list (INCI names): All cosmetic ingredients must be listed in descending order of concentration using INCI (International Nomenclature of Cosmetic Ingredients) names. This must appear on both the product page and the packaging.
  • Function and use description: The intended use of the cosmetic product must be clearly described. Products that make medicinal claims risk being reclassified as medicines and subject to pharmaceutical regulation.
  • Safety Assessment: A Cosmetic Product Safety Report (CPSR) must be prepared by a qualified safety assessor and kept on file by the Responsible Person.

Category 5: Food contact materials

Products that come into contact with food — kitchen utensils, cookware, food storage containers, packaging — are regulated under EC 1935/2004 and specific measures for materials such as plastics (EU 10/2011) and ceramics:

  • Declaration of Compliance (DoC): A written declaration that the material complies with applicable EU food contact regulations must be available and provided to business customers in the supply chain. For direct-to-consumer ecommerce, the DoC should be available on request and referenced in the product information.
  • Migration testing: Specific migration limits apply for certain substances such as plasticisers and heavy metals from ceramic glazes. Non-EU manufacturers supplying to the EU market must demonstrate that migration testing has been conducted and limits are met.
  • Traceability: Food contact materials must be traceable at all stages of the supply chain. Batch-level traceability is effectively required, aligning with GPSR's product identifier requirements.
  • Labelling: Products must be labelled "for food contact" or carry the fork-and-glass symbol. The name or trade name of the manufacturer or importer must appear on the labelling.

Cross-category GPSR requirements all sellers share

Regardless of which category your products fall into, the baseline GPSR requirements apply universally. These are the obligations that market surveillance authorities check first, because they are the easiest to verify with an automated digital sweep:

  • Manufacturer information: Legal name, registered address, and electronic contact must appear on every product page.
  • Product identifier: A model number, batch number, SKU, EAN, or GTIN must be visibly displayed on each product listing.
  • EU Responsible Person: Required for all non-EU manufacturers. Details must appear on product pages alongside the manufacturer information.
  • Safety information in local language: Any safety warnings, age restrictions, or usage instructions must be provided in the official language(s) of the markets where you sell.

EuroGPSR checks your product pages for the most critical GPSR compliance signals — manufacturer information, product identifiers, EU Responsible Person details, legal pages, cookie consent, and over 20 EAA accessibility checks — regardless of which product category you sell in. Run a free scan to get a scored compliance report and a clear view of which requirements you are currently meeting and which need attention.

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