GPSR for Pakistani Exporters: What the EU Product Safety Rules Require

Which products GPSR covers

GPSR covers any product intended for consumers, or likely to be used by them, where no other EU law with the same safety objective covers the risk (Article 2). Where a sector law covers some risks, GPSR covers the rest. Food, medicines, feed, living plants and animals and a few other groups are outside it.

For Pakistani exports that means clothing, home textiles, towels, bags, leather goods, kitchen textiles and sports goods sold to consumers. Products under their own EU safety law, such as toys and personal protective equipment, follow that law first, and GPSR fills the gaps. Restricted chemicals in textiles are covered by REACH.

The regulation replaced the General Product Safety Directive 2001/95/EC, repealed from 13 Dec 2024 (Article 50). Safety Gate, the EU alert system for dangerous products, recorded 4,137 alerts in 2024, the highest since it started in 2003 (European Commission, 16 Apr 2025).

Who is the manufacturer: own brand or buyer's brand

Under GPSR the manufacturer is whoever makes a product, or has it made, and markets it under their own name or trademark (Article 3(8)). A company that places a product on the market under its name or trademark carries the manufacturer's duties even if it made nothing (Article 13(1)).

The EU responsible person

A product covered by GPSR cannot be placed on the EU market unless an economic operator established in the EU is responsible for it (Article 16). That operator is one of the four set out in Regulation (EU) 2019/1020, Article 4:

• a manufacturer established in the EU;

• an importer, where the manufacturer is not in the EU;

• an authorised representative with a written mandate from the manufacturer; or

• a fulfilment service provider in the EU, for the products it handles, where none of the others exists.

Where the product's risks call for it, the responsible person regularly checks that the product matches its technical documentation and its labelling, and gives the authorities documented evidence of those checks on request. Its name, postal and electronic address go on the product or its packaging, the parcel or an accompanying document. A company established only in Pakistan cannot fill this role; it has to be someone established in the EU.

What a manufacturer has to do under Article 9

• Risk analysis and technical documentation. Before sale, carry out an internal risk analysis and draw up technical documentation: a description of the product, the risks and how they were reduced, the outcome of any test reports, and the European standards applied. Keep it up to date and available to authorities for 10 years after the product is placed on the market.

• Product identification. A type, batch or serial number, easily visible and legible, on the product, or on the packaging or an accompanying document where the product is too small.

• Contact details. Name, registered trade name or trademark, postal address and electronic address on the product, or on the packaging or an accompanying document where that is not possible.

• Instructions and safety information in a language consumers in the selling country can easily understand, unless the product is safe to use without them.

• Series production. Procedures that keep every unit of a production run as safe as the one assessed.

• Problems. Where a product placed on the market is dangerous, take corrective action at once, including withdrawal or recall, inform consumers, and notify the authorities through the Safety Business Gateway. Accidents causing death or serious harm to health are also notified there (Article 20).

What an EU label must carry

Importers may add their own label, but it must not cover information another EU law requires on the manufacturer's label (Article 11(3)). Fibre composition labelling stays under Regulation (EU) No 1007/2011.

Selling online: Amazon, Etsy and other marketplaces

Every online offer to EU consumers must show, clearly and visibly (Article 19):

• the manufacturer's name or trademark, and postal and electronic address;

• where the manufacturer is outside the EU, the name, postal and electronic address of the EU responsible person;

• information that identifies the product, including a picture, its type and any other identifier; and

• any warning or safety information that has to appear on the product or its packaging, in a language consumers in that country can easily understand.

Marketplaces have their own duties under Article 22, including a single contact point registered on the Safety Gate Portal and internal product safety processes.

How a product is shown to be safe

A product is presumed safe for the risks covered by a European standard whose reference has been published in the Official Journal, if it conforms to that standard (Article 7). Where no such standard exists, national safety requirements apply. Article 6 lists what an assessment must consider, among them the product's design and composition, its labelling and age warnings, its users, especially children and older people, and whether its appearance could lead to misuse, such as a non-food item that looks like food.

Test reports are the evidence that goes into the technical documentation. Methods on the Tti Labs ISO/IEC 17025 scope (PNAC LAB-022) that cover chemical and accessory risks in consumer textiles include:

GPSR checklist for a Pakistani exporter

• Decide, product by product, who the manufacturer is under Article 3(8), and write it into the contract

• For own-brand goods, name the EU responsible person and confirm it accepts the role in writing

• Put a type, batch or lot number on every product, matched to production and test records

• Print the manufacturer's and responsible person's postal and electronic addresses on the product, packaging or accompanying document

• Keep a risk analysis and the test reports for each product, ready for 10 years

• Supply warnings and care or safety instructions in the language of each selling country

• Check marketplace listings for the Article 19 details, picture and identifier

• Keep a route for complaints and accidents, so the manufacturer can act and notify without delay

• Check labels, batch numbers and packing at pre-shipment inspection

How Tti Labs supports GPSR compliance

Tti Labs runs accredited tests under PNAC LAB-022 (ISO/IEC 17025, valid until 8 Aug 2027) that feed the technical documentation. Its product safety audit reviews risk management across sourcing, production, quality assurance, labelling and product release, to find gaps before products reach the market. Each test and its charge are confirmed in writing, with the turnaround, before any work starts (Tti Labs testing).

Tti Labs is based in Pakistan, so it cannot act as the EU responsible person. For products under sector laws, such as PPE, the certification page covers CE marking support, and the lab testing guide covers how to plan a test programme.

Ask Tti Labs about a product safety audit