The GPSR is Regulation (EU) 2023/988 on general product safety. It has applied since 13 December 2024, repealed the General Product Safety Directive 2001/95/EC and, as a regulation, applies directly in every Member State. Its core rule is short: businesses may only place or make available safe products on the EU market. Source: the European Commission’s guidelines for businesses on the GPSR, published in November 2025.
Which Products the GPSR Covers
The GPSR covers consumer non-food products, new or used, whichever channel sells them: shops, webshops and other distance sales. It works as a safety net, so where a specific EU law regulates the safety of a product, that law comes first and the GPSR fills the gaps.
Fan merchandise such as pins, keyrings, scarves or mugs is bought by consumers, so we treat it as in scope; the Commission’s guidelines do not name these items. Toys are the main exception in a merchandise range, because the toy safety rules govern them. Products that met the old directive and were placed on the market before 13 December 2024 may still be sold.
Who Is the Manufacturer Under the GPSR
The manufacturer is any person who makes a product, or has it designed or made, and markets it under its own name or trademark. Whose name is on the product decides the role, not who runs the machines.
A club that orders crest keyrings from a partner factory and sells them in its stadium shop is therefore the manufacturer. Before the first unit goes on sale it needs an internal risk analysis and technical documentation for each product, kept for 10 years after the product was placed on the market, as the Commission’s guidelines set out. For licensed products the trademark often belongs to the licensor, so settle in writing who markets which product under which name before the first delivery. For plated pins and keychains, our guide to GPSR and nickel rules for metal pins and keychains lists the test reports to ask a supplier for.
The Responsible Person in the EU
A product covered by the GPSR may only be placed on the EU market if a responsible economic operator, the “responsible person”, is established in the EU. A manufacturer established in the EU fills the role itself; otherwise it can be the importer, an authorised representative with a written mandate, or a fulfilment service provider.
The responsible person’s name, registered trade name or trademark and postal and electronic address must appear on the product, its packaging, the parcel or an accompanying document. A brand outside the EU that ships straight to fans in Germany or France needs this role settled before the first parcel leaves.
Product Identification and Contact Details
Every product needs a type, batch or serial number or another identifier such as a barcode, plus the manufacturer’s name, registered trade name or trademark and a postal and electronic address. The details belong on the product itself; usually only its size justifies moving them to the packaging or an accompanying document.
For a small enamel pin that usually means the backing card or the bag. An electronic address can be an e-mail address or a contact section on a website, but a website that does not allow direct contact is not enough. Instructions and safety information are needed only where the product cannot be used safely without them.
Selling Merchandise Online
An online offer must show the manufacturer’s name and contact details, the responsible person if the manufacturer sits outside the EU, a picture and the type or other identifier of the product, and any warning or safety information. The same information a fan would find on the product in a shop must be visible before the purchase.
The rules apply when an offer targets consumers in the EU, which is judged case by case. The Commission names the factors: the areas the seller ships to, the languages of the offer, the means of payment, and the use of an EU currency or a domain registered in a Member State. A club webshop with a euro checkout that delivers across the EU meets them.
Frequently Asked Questions
Does the GPSR apply to merchandise?
Merchandise sold to consumers is a consumer product, so the GPSR applies unless a specific EU law covers its safety, as the toy rules do for toys. The Commission’s guidelines do not list pins, keyrings or medals by name, which is why we read them as covered rather than exempt.
Who is the manufacturer when a club orders keyrings?
The club, if the keyrings are marketed under its name or trademark. The factory that makes them does not take over the manufacturer’s duties, such as the risk analysis, the technical documentation and the product identification.
How long must the technical documentation be kept?
For 10 years after the product has been placed on the market, and it must be available to market surveillance authorities on request. The same period applies to the internal risk analysis.
Does the GPSR replace REACH?
No. The GPSR sets the general safety duty and the traceability rules, while REACH restricts chemicals such as nickel in metal goods. A plated keyring has to meet both.
<nav class="article-breadcrumb"><a href="https://www.amball.com/magazine">Magazine</a><span class="article-breadcrumb__sep">/</span><a href="https://www.amball.com/glossary">Glossary</a><span class="article-breadcrumb__sep">/</span><span class="article-breadcrumb__current">GPSR (EU General Product Safety Regulation)</span></nav> <h1 class="article-h1">GPSR (EU General Product Safety Regulation)</h1> <p class="article-byline"><span class="cluster-badge">Licensing, Manufacturing & Compliance</span> · Updated October 19, 2026</p> <div class="article-intro"><p>The GPSR, Regulation (EU) 2023/988, is the EU's General Product Safety Regulation. Since 13 December 2024 it has set the safety, traceability and information duties for consumer products sold in the EU, in shops or online.</p></div> <ul><li>The GPSR, Regulation (EU) 2023/988, has applied since 13 December 2024 to consumer products and repealed the General Product Safety Directive 2001/95/EC.</li><li>The manufacturer is whoever markets a product under its own name or trademark, so a club selling crest keyrings in its shop takes that role even when a factory makes them.</li><li>A product may only be placed on the EU market if a responsible person is established in the EU, and products, packaging or online offers must show who the manufacturer is and how to reach it.</li></ul><p>The GPSR is Regulation (EU) 2023/988 on general product safety. It has applied since 13 December 2024, repealed the General Product Safety Directive 2001/95/EC and, as a regulation, applies directly in every Member State. Its core rule is short: businesses may only place or make available safe products on the EU market. Source: the European Commission’s <a href="http://data.europa.eu/eli/C/2025/6233/oj">guidelines for businesses on the GPSR</a>, published in November 2025.</p><h2>Which Products the GPSR Covers</h2><p>The GPSR covers consumer non-food products, new or used, whichever channel sells them: shops, webshops and other distance sales. It works as a safety net, so where a specific EU law regulates the safety of a product, that law comes first and the GPSR fills the gaps.</p><p>Fan merchandise such as pins, keyrings, scarves or mugs is bought by consumers, so we treat it as in scope; the Commission’s guidelines do not name these items. Toys are the main exception in a merchandise range, because the <a href="https://www.amball.com/glossary/toy-safety-testing-en71">toy safety rules</a> govern them. Products that met the old directive and were placed on the market before 13 December 2024 may still be sold.</p><h2>Who Is the Manufacturer Under the GPSR</h2><p>The manufacturer is any person who makes a product, or has it designed or made, and markets it under its own name or trademark. Whose name is on the product decides the role, not who runs the machines.</p><p>A club that orders crest keyrings from a partner factory and sells them in its stadium shop is therefore the manufacturer. Before the first unit goes on sale it needs an internal risk analysis and technical documentation for each product, kept for 10 years after the product was placed on the market, as the <a href="http://data.europa.eu/eli/C/2025/6233/oj">Commission’s guidelines</a> set out. For licensed products the trademark often belongs to the licensor, so settle in writing who markets which product under which name before the first delivery. For plated pins and keychains, our guide to <a href="https://www.amball.com/magazine/gpsr-nickel-metal-pins-keychains-eu">GPSR and nickel rules for metal pins and keychains</a> lists the test reports to ask a supplier for.</p><h2>The Responsible Person in the EU</h2><p>A product covered by the GPSR may only be placed on the EU market if a responsible economic operator, the “responsible person”, is established in the EU. A manufacturer established in the EU fills the role itself; otherwise it can be the importer, an authorised representative with a written mandate, or a fulfilment service provider.</p><p>The responsible person’s name, registered trade name or trademark and postal and electronic address must appear on the product, its packaging, the parcel or an accompanying document. A brand outside the EU that ships straight to fans in Germany or France needs this role settled before the first parcel leaves.</p><h2>Product Identification and Contact Details</h2><p>Every product needs a type, batch or serial number or another identifier such as a barcode, plus the manufacturer’s name, registered trade name or trademark and a postal and electronic address. The details belong on the product itself; usually only its size justifies moving them to the packaging or an accompanying document.</p><p>For a small enamel pin that usually means the backing card or the bag. An electronic address can be an e-mail address or a contact section on a website, but a website that does not allow direct contact is not enough. Instructions and safety information are needed only where the product cannot be used safely without them.</p><h2>Selling Merchandise Online</h2><p>An online offer must show the manufacturer’s name and contact details, the responsible person if the manufacturer sits outside the EU, a picture and the type or other identifier of the product, and any warning or safety information. The same information a fan would find on the product in a shop must be visible before the purchase.</p><p>The rules apply when an offer targets consumers in the EU, which is judged case by case. The Commission names the factors: the areas the seller ships to, the languages of the offer, the means of payment, and the use of an EU currency or a domain registered in a Member State. A club webshop with a euro checkout that delivers across the EU meets them.</p><h2 id="frequently-asked-questions">Frequently Asked Questions</h2><h3>Does the GPSR apply to merchandise?</h3><p>Merchandise sold to consumers is a consumer product, so the GPSR applies unless a specific EU law covers its safety, as the toy rules do for toys. The Commission’s guidelines do not list pins, keyrings or medals by name, which is why we read them as covered rather than exempt.</p><h3>Who is the manufacturer when a club orders keyrings?</h3><p>The club, if the keyrings are marketed under its name or trademark. The factory that makes them does not take over the manufacturer’s duties, such as the risk analysis, the technical documentation and the product identification.</p><h3>How long must the technical documentation be kept?</h3><p>For 10 years after the product has been placed on the market, and it must be available to market surveillance authorities on request. The same period applies to the internal risk analysis.</p><h3>Does the GPSR replace REACH?</h3><p>No. The GPSR sets the general safety duty and the traceability rules, while <a href="https://www.amball.com/glossary/reach">REACH</a> restricts chemicals such as nickel in metal goods. A plated keyring has to meet both.</p><hr class="faq-end"> <section class="related-section"><h2>Related Glossary Terms</h2><div class="related-grid"><a href="https://www.amball.com/glossary/reach" class="related-card"><p class="related-label">Licensing, Manufacturing & Compliance</p><p class="related-title">REACH (EU Chemicals Regulation)</p><p class="related-snippet">REACH is the EU's core chemicals regulation, controlling which substances can be used in a product sold into the EU and how their presence has to be disclosed. For merchandise, the parts that matter most are the Substances of Very High Concern (SVHC) disclosure duty and specific Annex XVII restrictions like the nickel release limit on metal goods.</p></a><a href="https://www.amball.com/glossary/ppwr" class="related-card"><p class="related-label">Licensing, Manufacturing & Compliance</p><p class="related-title">PPWR (EU Packaging and Packaging Waste Regulation)</p><p class="related-snippet">PPWR (Regulation (EU) 2025/40) is the EU's Packaging and Packaging Waste Regulation. It applies from 12 August 2026 to all packaging placed on the EU market, including the gift boxes, polybags and cartons used for merchandise.</p></a></div></section> <section class="from-blog-section"><h2>From the Magazine</h2><a class="from-blog-link" href="https://www.amball.com/magazine/gpsr-nickel-metal-pins-keychains-eu">GPSR and Nickel Rules for Metal Pins and Keychains</a><a class="from-blog-link" href="https://www.amball.com/magazine/quality-control-metal-merchandise-checklist">Quality Control for Metal Merchandise: A Checklist</a></section>
