Checklist: Launching a New Product in the EU (2026 Edition)
This 2026 checklist is designed for brands that want to place consumer products on the EU market and stay aligned with the General Product Safety Regulation (GPSR, Regulation (EU) 2023/988). It complements our previous 2025 edition and reflects current enforcement practice under the EU compliance framework for consumer products.
You can download our General Product Safety Regulation checklist here. This checklist gives you a structured overview of the key requirements and documentation needed to support compliance with the EU GPSR (General Product Safety Regulation). Use it to guide your preparation of risk assessments, labeling, technical files, and other core elements of a compliant product safety file. Implementing the items in this checklist early can help prevent gaps and streamline your overall GPSR compliance process.
1) Confirm which EU rules apply to your product
Map your product category and legal framework
Start by identifying whether your product is covered only by GPSR or also by specific EU harmonisation legislation (such as toys, electrical products, radio equipment, cosmetics, medical devices, PPE, machinery, construction products, or food contact materials). If a specific legal framework applies, it usually brings additional technical file elements, markings, and declarations (see our guide on Toy Safety in the EU where relevant).
Define your target markets and sales channels
List the EU countries you will sell to and where you will sell (own website, Amazon, Etsy, eBay, retail, distributors). This affects language requirements, packaging and environmental rules, and marketplace documentation expectations. If you sell via marketplaces, review Amazon EU sales and GPSR requirements and our guide on how to sell to the EU as a non-EU seller.
2) Build a compliant product identity and traceability setup
Assign unique product identifiers
Ensure each product has a clear identifier (SKU, model number, batch/lot number, or serial number where relevant). The goal is that you can trace production batches and respond quickly if there is a safety complaint or recall.
Define economic operators
Clarify who is the manufacturer, importer, distributor, and (if required) the EU Responsible Person under GPSR. These roles are not just labels, they decide who must hold documents and respond to authorities.
3) Perform a structured risk assessment (the core GPSR deliverable)
Identify hazards and foreseeable misuse
Document hazards across relevant areas (mechanical, choking, sharp edges, chemical, flammability, electrical, overheating, microbiological where relevant, and user information risks). Include foreseeable misuse (what users commonly do, not just what the manual says). See the full GPSR risk analysis process and our article on product age grading in the EU.
Define risk controls and residual risk
For each hazard, document how you reduce risk (design changes, material controls, warnings, instructions, packaging controls, quality checks). Confirm what residual risk remains and why it is acceptable for consumers. See practical GPSR warning examples.
Use standards as evidence where appropriate
Where EU harmonised standards or widely accepted reference standards exist, use them to support your safety rationale. Keep a record of the edition/year used and which clauses are relevant to your product.
4) Collect supplier evidence and test reports
Validate materials and chemical compliance
Collect and archive relevant test reports and supplier declarations (for example REACH, RoHS, and POPs testing, nickel release, heavy metals, etc.). Where chemicals are involved, review Safety Data Sheets (SDS). Generic supplier statements without test scope detail are often not sufficient.
Always request compliance documents
Always request compliance documents. If you do not have them, your supplier should:
- Product description and pictures
- Current artwork (packaging, labeling, etc.)
- Bill of materials
- Any pre-existing supplier declarations
- Test reports
- Any other relevant compliance documents (e.g., certifications, Safety Data Sheets)
5) Prepare and maintain the technical documentation (technical file)
What to include in a practical GPSR technical file
Your file should typically include product description, bill of materials, design specifications, risk assessment, test reports, labels and packaging proofs, instructions and warnings, supplier compliance evidence, and internal quality controls. See our detailed GPSR Technical File Guide.
Retention and availability
Keep documentation accessible and ready to provide to EU market surveillance authorities on request. Non-compliance can result in penalties (see GPSR penalties guide and what happens if you don’t comply).
6) Appoint an EU Responsible Person if you are non-EU
When an EU Responsible Person is required
If your business is outside the EU and you sell to EU consumers, you typically need an EU-based GPSR Responsible Person. Read more about appointing an EU Responsible Person.
Lifecycle responsibility
Following certification, EaseCert will act as the designated EU Responsible Person for the product's entire lifecycle on the EU market, without recurring fees.
7) Draft the Declaration of Conformity or compliance declaration
What it should contain
Prepare a declaration aligned with the EU Declaration of Conformity guide. Ensure alignment between product identifiers and documentation.
8) Ensure labels, warnings, and instructions are correct
Mandatory product and packaging information
Review labelling requirements under GPSR and confirm your warnings are compliant using warning examples.
9) Prepare for marketplace compliance and Safety Gate expectations
EU Safety Gate registration
Clients who sell online need to register at the EU Safety Gate Online Marketplace Module. EaseCert offers an EU Safety Gate Registration Service. With this, we act as the main contact for market surveillance authorities. This is legally required for online sellers.
Prepare for product liability and recalls
We need to be prepared for the upcoming EU Product Liability Directive. In worst case, a recall may be necessary (see how to handle a product recall and new EU recall requirements). EaseCert helps prevent this risk by managing direct communication with authorities.
10) After launch: keep compliance alive
Packaging and EPR obligations
Beyond product safety, you may need environmental registrations such as WEEE registration or packaging schemes. For Germany, review LUCID registration. For France, see Triman (Info-Tri) guidance.
Each certification includes the following:
- Comprehensive risk assessment tailored to the products to identify safety issues and demonstrate EU compliance. See our risk analysis template for reference.
- Creation of a Technical File, containing all required compliance documentation. This file serves as the central compliance record.
- Creation of customized multi-language product label for each group including safety warnings originating from the risk analysis. See label template for reference.
For EPR (packaging), we can also help with France Triman (Info-Tri) Labelling Requirements and LUCID Registration Guide – Packaging Compliance in Germany.
Frequently Asked Questions
Does GPSR apply to all consumer products sold in the EU?
Yes. The General Product Safety Regulation (EU) 2023/988 applies to all consumer products placed on the EU market, unless a specific EU harmonisation law already governs the product (such as toys, medical devices, or radio equipment). Even where sector-specific rules apply, general safety expectations and market surveillance obligations remain relevant. See our broader EU compliance guide for consumer products.
What documents do I need before selling in the EU?
At minimum, you need a structured risk assessment, a complete technical file, compliant labelling, and a declaration aligned with applicable legislation. Learn more in our GPSR Technical File & Product Compliance Guide and the detailed Technical File Documentation Guide.
What if I do not have compliance documents?
In most cases, your supplier or manufacturer already has at least part of the documentation. You should always request:
- Product description and images
- Artwork and label proofs
- Bill of Materials (BOM)
- Supplier declarations
- Test reports
- Safety Data Sheets (SDS), where applicable
If the supplier cannot provide evidence, additional testing or documentation work is required before market placement.
Do I need an EU Responsible Person?
If your company is established outside the EU and you sell to EU consumers (including via Amazon or other platforms), you typically need an EU-based Responsible Person. This ensures authorities and consumers can identify an accountable economic operator inside the EU. Read: Why You Need a GPSR Responsible Person.
Following certification, EaseCert can act as the designated EU Responsible Person for the entire lifecycle of the product on the EU market.
Is EU Safety Gate registration mandatory for online sellers?
Yes. Businesses selling through online marketplaces must register in the EU Safety Gate Online Marketplace Module. EaseCert offers a dedicated EU Safety Gate Registration Service and can act as the main contact for EU market surveillance authorities.
What happens if I do not comply with GPSR?
Authorities can request documentation, restrict sales, order product withdrawal, or impose fines. In serious cases, a product recall may be required. See: What Happens If You Don’t Comply with GPSR and GPSR Penalties Explained.
What is the risk under the new EU Product Liability Directive?
The updated EU Product Liability Directive increases exposure for manufacturers, importers, and authorised representatives. Proper documentation, traceability, and structured risk management significantly reduce this risk.
Do I also need packaging or environmental registrations?
Possibly. Beyond product safety (GPSR), you may need packaging or environmental registrations such as LUCID registration in Germany, WEEE registration, or France Triman requirements. These are separate from product safety but often mandatory before sale.
How much does GPSR compliance cost?
Costs depend on product category, risk level, documentation availability, and the number of product groups. You can review typical pricing structures here: Understand GPSR Cost & Responsible Person Cost.
Where can I get support?
Review what we offer, browse our FAQ section, or contact us directly to discuss your product category.
Need support?
Explore what we offer, review our GPSR compliance services, check typical GPSR and Responsible Person costs, browse our FAQ, or contact us directly.
