Since December 2024, a consumer product may be placed on the EU market only if there is an EU-established economic operator responsible for it. For a manufacturer outside the EU that is not a formality to add later. Without one, the product cannot lawfully be sold, and marketplaces enforce it before any authority does.
What GPSR requires
Regulation (EU) 2023/988, the General Product Safety Regulation, has applied since 13 December 2024. It replaces the old general product safety directive and covers consumer products that no more specific EU legislation already governs, which is where most containers sold to end users sit.
The obligation that catches non-EU manufacturers is the responsible person: an economic operator established in the EU, appointed to carry defined product-safety duties.
- Named as the contact point for market surveillance authorities
- Holding access to the technical documentation, and able to supply it on request
- Checking compliance and keeping documented evidence of having done so
- Authority to act on the manufacturer’s behalf on safety matters
Their contact details must appear on the product or its packaging, on the parcel, or in an accompanying document. This is the part that shows up as a listing suspension, because marketplaces check for it.
Who actually holds the role in a container supply chain
It depends on how the goods reach the consumer, and getting this wrong is the usual failure.
| How you sell | Who is normally the responsible person |
|---|---|
| You import into the EU and resell under your own brand | You. Importing under your brand makes you the manufacturer for these purposes |
| You import and resell the manufacturer’s brand | You, as the EU importer, unless an authorised representative is appointed |
| A non-EU manufacturer sells direct to EU consumers | An appointed EU authorised representative or fulfilment service provider |
| Business-to-business sale, never reaching a consumer | GPSR is aimed at consumer products; check whether your channel is genuinely B2B throughout |
What it does not replace
GPSR sits alongside everything else rather than instead of it. A fuel container still needs UN approval to move as dangerous goods, still meets the destination market’s own container rules, and still answers the packaging and EPR regime. GPSR asks a different question: is there an accountable operator inside the EU, and is the product safe for a consumer to use.
What to have ready
- The appointed responsible person, named, with contact details on pack or in the documentation
- Technical documentation for the product, accessible to them
- A risk assessment appropriate to the product and its foreseeable use
- Traceability: batch or model identification that lets a specific run be found
- Clear warnings and instructions in the language of the member state where it is sold
Where we stand on this
Plainly, and with one legal point first. The responsible person must be established in the EU, so no manufacturer outside the Union can be one, us included. That is a feature of the regulation rather than a gap in our capability, and any overseas supplier claiming to act as your responsible person has misread it.
What we do is make the role straightforward to fill. The person appointed needs access to technical documentation and has to be able to evidence compliance checks. We supply that file:
- Full specification and material identification for the design
- Test and inspection reports where they apply to your product
- UN certification for dangerous-goods designs, with the certificate number and the plant named on it
- ISO 9001, ISO 14001, ISO 45001, covering quality, environmental and occupational health and safety management
- Batch or run identification, so a specific production run is traceable
- Labelling built to carry your responsible person’s details, applied in line rather than as a sticker
That last one is why this belongs at enquiry rather than after. Contact details on pack means artwork, which means tooling and print, which is settled before production. Tell us who the responsible person will be and we build the labelling around them from the first run. If the role is not appointed yet, tell us that too, because it is the one thing that has to be resolved before goods can lawfully be sold and it is quicker to arrange than to unwind a suspended listing.
Where to start
| Your use case | Recommended can | Why this one |
|---|---|---|
| Consumer and retail fuel |  20L NATO Steel Fuel Can |
Where GPSR labelling lands hardest. |
| Consumer safety features |  Child-Resistant Closures |
A closure choice with a safety rationale behind it. |
| Consumer water storage |  20L Stainless Steel Water Can |
Retail channel, so consumer rules apply. |
| Accessories sold at retail |  Jerry Can Holders & Mounts |
In scope too; the rules follow the channel. |
Common questions
What is a GPSR responsible person?
An economic operator established in the EU, appointed to carry defined product-safety duties: acting as contact point for market surveillance authorities, holding access to the technical documentation, checking compliance and keeping evidence of it, and having authority to act on the manufacturer behalf on safety matters.
Does a non-EU manufacturer need an EU responsible person?
Yes, for consumer products. Since 13 December 2024 a consumer product may be placed on the EU market only if an EU-established economic operator is responsible for it. Without one the product cannot lawfully be sold, and online marketplaces enforce this before any authority does.
Where must the responsible person contact details appear?
On the product or its packaging, on the parcel, or in an accompanying document. This is the requirement that most often surfaces as a marketplace listing suspension, because it is machine-checkable in a way the rest of the regulation is not.
Who is the responsible person when I import containers into the EU?
Normally you. Importing under your own brand makes you the manufacturer for these purposes; importing and reselling the maker brand makes you the EU importer carrying the role, unless an authorised representative is appointed. A non-EU manufacturer selling direct to consumers needs an appointed representative or fulfilment service provider.
Does GPSR replace UN packaging approval?
No. GPSR sits alongside the rest. A fuel container still needs UN approval to move as dangerous goods, still meets the destination market container rules and still answers the packaging and EPR regime. GPSR asks a different question: is there an accountable operator inside the EU, and is the product safe in consumer use.
References
The standards and regulations this page relies on, at their issuing body. Where a market rule is named here, check the current revision before you specify against it.
Last reviewed .