What does the EU GPSR actually require sellers to do?
The General Product Safety Regulation (Regulation 2023/988) replaced the 2001 Directive on 13 December 2024. The full text is on EUR-Lex Regulation 2023/988. The European Commission's GPSR guidance page summarises the operator obligations.
Three articles carry the core obligations for an Amazon EU seller:
- Article 10 — Responsible Person designation. Any product placed on the EU market must have an economic operator established in the EU who accepts compliance responsibility. For a non-EU seller, this is the Responsible Person (RP). The RP is a real legal entity named on packaging, holds the technical file, and is the contact point for market surveillance authorities. Article 10 covers the obligations of importers and other economic operators; the RP role is the practical implementation for non-EU sellers.
- Article 9 — manufacturer obligations. Risk assessment, technical documentation, traceability identifier on the product, instructions and safety information in the official languages of each member state where the product is sold.
- Article 17 — online marketplace obligations. Online marketplaces are required to verify that sellers provide the RP contact and traceability data before listing, and to act on Safety Gate notifications. CE marking is a product conformity mark under applicable product-specific directives (e.g., Low Voltage Directive, EMC Directive) — it is not a GPSR compliance mark specifically. Whether CE marking applies to a given product depends on the applicable directive for that product category, not on GPSR alone.
For product categories that require third-party conformity assessment, the NANDO EU Notified Bodies database identifies the relevant notified bodies. NANDO is most relevant for categories with directive-mandated third-party assessment — not every consumer product requires a NANDO-listed notified body under GPSR.
How does Amazon enforce GPSR differently from the EU regulation?
Amazon Seller Central documents the enforcement path under Amazon's GPSR compliance guidance.
Per Amazon's published documentation, two mechanics are described:
- Account-level Responsible Person. Configured in Manage Your Compliance. Amazon's documentation states that the account-level RP must be in place before per-ASIN compliance data is evaluated. This is why bulk uploads in many seller-reported cases return 100% rejection when Layer 1 is missing — Amazon's enforcement flow gates per-ASIN processing on the account-level RP state.
- Per-ASIN compliance fields PS01–PS06. Once the account-level RP is active, each ASIN takes a technical file via Amazon's compliance feed file or the per-ASIN UI: PS01 manufacturer reference, PS02 risk assessment summary, PS03 warnings and hazard pictograms, PS04 contact details, PS05 traceability identifier, PS06 declaration of conformity reference.
Per Amazon's GPSR documentation, the marketplace in many cases blocks listings missing PS01–PS06 data from search and buy box on Amazon.de, Amazon.fr, Amazon.it, Amazon.es, and Amazon.nl. Seller reports on r/AmazonFBA describe blocks rolling out in waves and re-listing as typically automatic once data is accepted — Amazon's internal processing timelines are not publicly documented.
What is the on-product layer?
Three on-product elements apply to most product categories under GPSR:
- RP contact details on the label. Name + EU address. Article 10 of Regulation 2023/988 names this obligation for economic operators placing products on the EU market. The label requirement applies to the product or the packaging if the product is too small.
- Traceability identifier. Batch number, serial number, or model number that links to the technical file.
- Safety information and instructions in the languages of the member states where the product is sold. German for Amazon.de, French for Amazon.fr, Italian for Amazon.it, Spanish for Amazon.es, Dutch for Amazon.nl.
A listing may pass the Amazon account-and-listing-layer block by having Layer 1 and Layer 2 in place. Market surveillance authorities can issue Safety Gate notifications if Layer 3 is missing on the physical product. Both enforcement channels are independent.
What's the 3-layer stack that gets a GPSR-blocked listing reinstated?
The Octo GPSR Compliance Stack is the methodology Octo applies. For an already-blocked seller, the recovery runs in this order. Skipping a step is the recurring reason recoveries stall.
| Step | Action | Why it comes here |
|---|---|---|
| 1 | Confirm or appoint the EU Responsible Person (Article 10) at the account level in Manage Your Compliance. RP must be a real EU-established legal entity named on packaging. | Per Amazon's documentation, if Layer 1 is missing, every ASIN-level submission is expected to fail. Bulk feeds return 100% rejection in this state. |
| 2 | Build the master technical-file sheet, keyed on manufacturer reference, not ASIN. One row per physical product. PS01 manufacturer reference, PS02 risk assessment, PS03 warnings + hazard pictograms, PS04 contact details, PS05 traceability ID, PS06 declaration of conformity. | The master is the single source of truth. Per-marketplace feeds are derived outputs. |
| 3 | Generate per-marketplace feeds with language coverage matching each Amazon EU site. One feed per marketplace, validated against PS01–PS06 schema. | Marketplaces have separate language requirements. A single feed across all five EU marketplaces typically fails on language validation. |
| 4 | Submit one marketplace first as a test. Wait for Amazon to accept or reject. Iterate on rejection codes before submitting the other four. | Testing one feed is cheap. Testing five at once and finding a schema error means rejecting all five and resubmitting. |
| 5 | Verify Layer 3 on the next production run. RP label per Article 10, traceability identifier, CE mark where the applicable product directive requires it, accessible technical documentation. | Amazon and market surveillance are independent enforcement channels. |
Layer agreement is the practical screen — Layer 1 active, Layer 2 submitted and accepted, Layer 3 verified on the product. None of these constitutes an Amazon-confirmed reinstatement guarantee. Amazon's review timeline is not officially published, and seller reports on r/AmazonFBA describe reinstatements ranging from same-day to multi-week depending on the rejection reason.
Quick diagnostic — if the bulk feed is returning 100%+ rejection:
| Check | What to look for |
|---|---|
| Account-level RP status | Is the RP active in Manage Your Compliance? |
| RP entity type | Is the RP a real EU-established legal entity, not a mailbox? |
| RP-account link | Is the seller account linked to the RP record? |
| One-ASIN manual test | Submit one ASIN manually — does it accept or reject? |
What does a 100% rejection rate likely signal?
A bulk feed that returns 100% rejection in most cases does not indicate a per-ASIN data error. The pattern Octo Pulse tracks in the r/AmazonFBA thread and adjacent posts suggests that 100% rejection is often a Layer 1 problem at the account level — the RP is not active, the RP is rejected by Amazon, or the seller account is not linked to the RP record.
The fix is not to scrub the per-ASIN data. The fix is to confirm Manage Your Compliance shows an active RP, then resubmit one ASIN manually. When the manual submission accepts, the bulk feed is likely to accept against the same Layer 1 state. When the manual submission still rejects, the error is at Layer 1.
This is sequencing, not data quality. 100% rejection is a Layer 1 signal in most cases observed in seller reports — not a data signal.
Editorial note
GPSR is real regulation with a working EUR-Lex citation. This article describes a practical recovery screen for sellers based on Amazon's published documentation and seller-reported patterns. It is not legal advice. Setting up an EU-established Responsible Person, drafting risk assessments, and confirming declaration-of-conformity scope are tasks for a qualified attorney, an EU-Authorized Representative service, or a regulatory compliance partner. The Octo GPSR Compliance Stack is methodology — it does not replace the legal review of Articles 9, 10, and 17 obligations against a specific product line.
How Octo helps
Octo Periscope monitors GPSR enforcement patterns across the five Amazon EU marketplaces and tracks rejection-reason distribution as reported by sellers week over week. SAM connects sellers to EU-Authorized Representative providers and to test labs and NANDO-listed notified bodies (for product categories where third-party assessment applies) for risk assessments and Declaration of Conformity drafting. The combination supports the unblocking process — monitoring data on what is blocking right now, plus operational connections to the compliance providers who can close the gap.