GPSR – General Product Safety Regulations
Under this neat acronym are new regulations for e-commerce and stationary stores, introduced under EP and Council Regulation (EU) 2023/988 of May 10, 2023.
What is the purpose of the regulation?
The regulation takes care to unify regulations on – among other things – product labeling, and regardless of where customers shop. The idea is to ensure that consumers receive exactly the same set of product information when shopping online as they do in a stationary store.
Who must comply with the new regulations?
GPSR regulations include:
- manufacturers of products belonging to selected categories,
- importers of the above,
- retailers,
- stationary stores,
- Online stores (including those embedded on sales platforms),
- providers of online trading platforms.
Responsibilities of distributors – that is, your store
All the most relevant obligations of distributors are detailed in Article 12 of Regulation 2023/988. They consist of four points.
First point
Distributors are required to verify that the manufacturer and/or importer has met the requirements set forth in Article 9, paragraphs 5-7 (manufacturer) and Article 11, paragraphs 3-4 (importer) of the Regulation. These include:
- Marking the products with identification markings,
- provision of the required manufacturer’s contact information,
- Include clear instructions on safety.
Second point
Distributors must ensure that while they are responsible for the product, its storage and transportation conditions meet the requirements set forth in Article 5 (and consequently Article 6) of the Regulation, and comply with the requirements set forth in Article 9 paragraphs 5-7 and Article 11 paragraphs 3-4.
Third point
If a distributor finds that a product it intends to market does not comply with the requirements listed above, it should withhold the release of that product on the market until the requirements are met.
Fourth point
If a distributor finds that a product that it has already made available on the market is unsafe or does not comply with the above requirements, it should:
- Inform the manufacturer or importer of the circumstances,
- Ensure that corrective measures are taken to bring the product into compliance, including, where warranted, the withdrawal of the product from the market and the recovery of the product from consumers to whom it has already been made available.
- Ensure that the situation is communicated to the market surveillance authorities of the Member States where the product has been made available on the market. The information should be provided using the Safety Business Gateway portal.
The described points in an e-commerce setting are realized, for example, by making the required product information available in the corresponding product card – to allow all customers to access the complete data from the store.
What information should be included in the product description?
In addition to standard data such as name, designation or product number, the following information should be included in each product sheet:
Manufacturer details
Data include mailing address, e-mail address, telephone number (if available). In a situation where the manufacturer does not operate in the European Union, it is necessary to provide the data of the person or entity responsible in the EU. In justified cases, it is permissible to include importer data (instead of manufacturer data) within this section.
Product safety markings
Information about approvals granted, certificates obtained, and all kinds of safety warnings in the form of clear messages. The idea is to include key information that is also on the product packaging or in the documents attached to the product.
Documentation
Downloadable documents – instructions, warranty cards, etc. – must also be available from the product card level of the online store from December 13, 2024.
Important!
The provisions of the GPSR regulation should be applied to products regardless of their condition. Stores should therefore take care to properly describe both brand-new products and used, after-sale or refurbished products.
Not complying with GPSR regulations? There will be consequences
With the adoption of Regulation 2023/988, EU member states were given the responsibility to adapt their laws in such a way as to be able to ensure enforcement of the new regulations. The instruments to ensure this include fines for entities neglecting the new obligations.
A draft amendment to the Law on General Product Safety is under way in Poland. Currently (as of March 27, 2025), the draft is being considered by the Committee for European Affairs. The draft includes a place for fines ranging from PLN 40,000 to PLN 1,000,000.
EAA – European Accessibility Act
The European Accessibility Act is a directive aimed at harmonizing accessibility requirements for digital products in the European Union. The EAA introduces new regulations for e-commerce (but also for other industries and sales models) in order to adapt products and services to the needs of people with disabilities across the EU.
Important!
The provisions of the EAA go into effect on June 28, 2025.
Who is affected by the new regulations?
The European Accessibility Act includes, among other things:
- manufacturers of products covered by the directive,
- importers bringing products from outside the EU to the EU market,
- distributors of covered products,
- service providers of services covered by the directive.
Important!
The authors of the document provided an important exception – micro-entrepreneurs who employ fewer than 10 people (including sole proprietors) are not covered by the provisions of the EAA Directive.
Products and services covered by the EAA
The directive does not cover all products and services. Only specified categories of products and services, considered essential for EU citizens, should be included in its initial period of application.
Categories of products covered by the European Accessibility Act
- computer hardware systems (including personal computers, desktops, laptops smartphones, tablets) and operating systems (Article 2(1a) of the Directive),
- Payment terminals – including equipment, software and self-service terminals with exceptions (Article 2, paragraph 1b),
- consumer terminal equipment for accessing electronic communications services – including routers and modems (Article 2, point 1c-d),
- e-book readers (Article 2, point 1e).
Categories of services covered by the European Accessibility Act
- electronic communications services (Article 2(2a) of the Directive),
- Services that enable access to audiovisual media services – websites, web applications, downloadable applications, mobile device-based services, media players, hybrid TV services (Article 2(2b)),
- Providing information on transportation services (Article 2, point 2c),
- retail banking services (Article 2.2d),
- electronic books (Article 2, point 2e),
- e-commerce services (Article 2, point 2f).
EAA and Polish law
The Act of April 26, 2024 on Ensuring Accessibility Requirements for Certain Products and Services by Business Entities has appeared in the Polish legal order. It is this document that regulates accessibility on the basis of the discussed Directive 2019/882 dated April 17, 2019.
Obligations under the European Accessibility Act
New regulations for e-commerce stem from the so-called Accessibility Act. Among them will be:
- The need to prepare and publish text descriptions for images, such as product photos (alternative text descriptions),
- The obligation to provide the ability to navigate the store’s website using a keyboard,
- The need to adapt websites to function on different devices,
- The requirement to apply standardized rules for text and background contrast.
This is not the end of responsibilities. Under the new regulations, it is also necessary to:
- Adapting mobile applications for use with screen readers (devices that read content from screens aloud) and adapting them to the needs of people with disabilities,
- providing the ability to communicate in all possible ways, including voice and text chats,
- Providing consumers with documentation, including product manuals, warranty cards or terms and conditions,
- Adapting the aforementioned for use with assistive technologies (such as the aforementioned screen readers),
- Constant monitoring of resources with regard to availability and compliance with EAA requirements, and making corrections on an ongoing basis,
- Organizing accessibility training for personnel responsible for operating sales platforms.
WCAG – Web Content Accessibility Guidelines
The European Accessibility Act is largely derived from the principles compiled in WCAG (Web Content Accessibility Guidelines) version 2.1 (although currently – as of March 27, 2025 – version 2.2 is the latest).
Pillars of WCAG
The Web content guidelines are based on four pillars:
- Perceivability – content should be designed so that it can be understood through the sense of sight and hearing,
- Functionality – Interface elements should be planned so that they can be handled with the keyboard,
- Comprehensibility – the guiding principle of content creation should be the ability to easily digest it,
- Robustness – content, interface elements and navigation mechanisms should be compatible with enabling technologies.
What does the future hold for e-commerce?
The above-described changes are all major ones that have occurred or will occur in 2025. This, however, does not mean that online store owners will be able to rest from new developments and regulations next year. On the contrary – a number of changes are already planned and are expected to take effect in 2026.
EGD, ESPR, DPP, and how do you find your way through it all?
It is not easy to discern all the applicable acronyms, so we will try to make their meaning as clear as possible.
EGD – European Green Deal.
The new regulations for e-commerce are also linked to the gradual implementation of the European Green Deal, a long-term strategy to make European Union countries climate-neutral by 2050.
ESPR – Ecodesign for Sustainable Products Regulation
One of the documents accompanying the EEZ is the EP and Council (EU) Regulation 2024/1781 dated. on ecodesign for sustainable products (this is its abbreviated name). For convenience, we will use the widely accepted abbreviation ESPR.
The regulation went into effect in July 2024, but implementation of some of its provisions has been staggered. The ESPR aims to bring products in line with the requirements of a climate-neutral economy, reduce the amount of waste produced and set new standards for sustainability.
DPP – Digital Product Passport (CPP – Digital Product Passport).
The idea behind the DPP is to give consumers the opportunity to make an informed choice. It’s a digital document where every customer will be able to find basic information about products before buying them. What kind of information is this?
- materials used,
- country/region of origin,
- environmental impact,
- disposal and recycling guidelines,
- Safety certificates and compliance with applicable standards,
- product composition.
When will the Digital Product Passport become mandatory? In 2026 for some products, such as batteries, textiles and electronics. Over time, it is expected that the categories of products covered by the digital passport will expand.
Summary
Starting this year, be aware of the provisions of the General Product Safety Regulations and the European Accessibility Act. In 2026, regulations related to the Digital Product Passport will be added. These are – at the moment – the three most important pieces of legislation in the context of changes applicable to entrepreneurs operating in the area of e-commerce.
However, it is worth keeping in mind that almost every year there are new regulations for e-commerce. So there is no need to wait for the last moment – the sooner you prepare for the changes, the easier it will be to adapt your business to operate in the new reality and you will not be surprised by another list of changes.
