SERVICES

EU-Based Authorised Representative Service

What is the GPSR?

The GPSR are the General Product Safety Regulations which extend the requirement to have mandatory  safety documentation to all other products not previously caught by bespoke legislation. 

Whilst it feels like there may be a number of hurdles to overcome to comply with the legislation, if you are already selling a product it is likely that you will already have much of the processes, procedures and paperwork in place already. 

Many products are already covered by technical documentation, such as electronics and toys, the sale of those products requires necessary technical documentation and certifications in place and the GPSR extends the approach to cover all consumer products. 

 

The requirement to provide technical documentation

The GPSR requires that technical documentation is created (if not already available) and that a copy is provided to an Authorised Representative who is based in the EU and can supply that documentation to authorities if requested. 

There are five key steps:

1. Consideration and description of the technical product information - as required under Article 9

2. Preparation of a risk assessment

3. Preparation of a recall protocol

4. Preparation of products in line with labelling requirements

5. Provision of all of the above documentation to an Authorised Representative. 

 

 

The legislation is designed to ensure the safety of all products sold in the EU. Predominately the legislation applies to physical goods.

On Wednesday 11th December 2024 in response to a direct question the European Commission confirmed that the legislation does apply to digital products. You can see the details here.  There is a downloadable Q&A document which states:

When does the GPSR apply?

The GPSR applies to all types of products (physical or digital products too, including software) that are placed or made available on the EU Single Market

This is new legislation so there is scope for interpretation. If you have any questions as to the applicability to you and your business you should seek legal advice. Lawyers across the EU are sharing their interpretation and we will be feeding back and updating information here. 

 

FAQs:

1. Do I need to take action now?

If your products are caught by the GPSR then yes, the legislation is in force now. 

2. What steps do I need to take?

You need to appoint an Authorised Representative based in the EU or Northern Ireland. You must provide them with details about the safety of your product. 

3. Do I need to get a representative in every EU member state? Or every state where I make a sale?

No. You just need one EU based representative.

4. How can you help?

We provide an EU based authorised representative service which you can join to comply with your legal obligations. Once you've subscribed you'll have representation for a year. At the point of purchase we'll send you a list of questions for you to answer and prompts for the documentation which we need so that you can provide us with information about your business, what you sell and the safety elements relating to it.

5. Will you become responsible for the safety of my products?

No. At all times you as the seller remain responsible for your products and providing the safety detail and keeping that information up-to-date.

6. How much is the EU authorised representative service?

€300/£250 per year for product portfolios with low risk profiles. Low risk products include cards, many crafting products and clothing. (Educational courses and digital downloads are considered low risk profile products.)

Higher rates will apply for more complicated products such as CE mark products, electronics, toys, children's products, cosmetics and medical and fitness products. Please get in touch for a bespoke quote if you consider your product profile to be medium or high risk.

7. Why is your service so much cheaper than some I've seen?

There are some representatives charging per product and per country. The type of product you are selling and the risk profile also increases the price. 

It is our aim to support UK businesses to promptly comply with their GPSR obligations. Until 31st January 2025 we have applied a flat rate for our authorised representative fee which is not dependent on volume of sales or the number of products in your portfolio. 

8. I'm not based in the UK, can you still help me?

Yes. This service can support any non-EU residents. If you're based in the US, Canada, Australia or anywhere outside of the EU you'll need an EU authorised representative. Please be aware that our services are conducted in English.

 

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