EU ecommerce compliance conversations often conflate two distinct regulations: the General Product Safety Regulation (GPSR) and the European Accessibility Act (EAA). They have different legal bases, different scopes, different enforcement authorities, and different penalties. If you operate an online store selling to EU consumers, you almost certainly need to comply with both — but for different reasons.
What each regulation covers
GPSR (Regulation EU 2023/988, in force from December 13, 2024) governs product safety. It requires that physical products sold to EU consumers are safe, that manufacturers and distributors are clearly identified, that products carry required information (identifiers, safety warnings, contact details), and that a recall mechanism exists. GPSR is primarily concerned with what you sell, not how you sell it.
EAA (Directive 2019/882, enforceable from June 28, 2025) governs digital accessibility. It requires that your website and app meet WCAG 2.1 Level AA accessibility standards — making your store usable for people with disabilities. The EAA is concerned with how you sell, not what you sell.
Who each regulation applies to
GPSR applies to anyone who places physical products on the EU market. The regulation covers manufacturers, importers, distributors, and fulfilment service providers. Microenterprises are not exempt from GPSR (though they may face reduced obligations in some circumstances).
The EAA applies to businesses providing "ecommerce services" — any website or app through which consumers can purchase products or services. Microenterprises (fewer than 10 employees and annual turnover below €2 million) are exempt from the EAA's service requirements, though not from requirements on the products themselves.
Key requirements compared
Under GPSR, your store must:
- Display the manufacturer's legal name and EU address on every product page
- Show a product identifier (model number, batch reference, or type designation)
- Provide an electronic contact point for the manufacturer
- Include applicable safety warnings in the language(s) of the countries where you sell
- Appoint an EU Responsible Person if the manufacturer is outside the EU
Under the EAA, your store must:
- Provide alt text for all meaningful images
- Meet 4.5:1 colour contrast ratio for text
- Label all form inputs with visible labels
- Support full keyboard navigation through the purchase flow
- Declare the page language in the HTML
- Not disable browser zoom (no user-scalable=no)
- Provide accessible error messages and status updates
Different enforcement, different penalties
GPSR is enforced by market surveillance authorities — in Germany the Bundesnetzagentur, in France the DGCCRF, in the Netherlands the NVWA. Penalties are primarily product-level: withdrawal from market, fines per violation, and public naming. Germany's ProdSG allows fines up to €100,000; the Netherlands up to €900,000; Italy up to €5,000,000.
The EAA is enforced by accessibility supervisory bodies designated by each member state. In Germany this falls to state-level authorities; in France to the ARCOM and DGCCRF; in Spain to the AEPD. Penalties are also significant: France allows fines up to €25,000, Spain up to €300,000, and the Netherlands up to €900,000.
Critically, a GPSR violation and an EAA violation are separately actionable — you can be fined by two different authorities for the same web page.
Do you need to comply with both?
In almost all cases, yes. If you operate an ecommerce store that sells physical products to EU consumers and you are not a microenterprise, both GPSR and EAA apply to you. The only exception is if your store sells only digital products (software, subscriptions, downloadable content) — in that case, GPSR's product-identification requirements do not apply to the digital products themselves, though the EAA's accessibility requirements still do.
Run a free scan to identify which specific GPSR and EAA requirements your store is currently missing.