GPSR and German EPR: What Importers Should Ask Their Supplier

GPSR and German EPR: What Importers Should Ask Their Supplier

Two pieces of European regulation now come up in nearly every sourcing conversation for home, gift and everyday goods: the EU General Product Safety Regulation (GPSR) and the German packaging law (VerpackG) with its LUCID register and Extended Producer Responsibility obligations.

Both place responsibility on the economic operator selling into the EU — which is usually the importer, not the factory. That makes them a supplier-assessment topic: the importer is legally accountable, but only the supplier holds the information needed to comply. The list below is written as questions to ask a supplier. It is general guidance, not legal advice; for a specific product, check with your compliance advisor or the relevant authority.

Part 1 — GPSR: The Basics

The GPSR (Regulation (EU) 2023/988) replaced the old General Product Safety Directive and has applied since 13 December 2024. It covers consumer products not already governed by a specific EU safety regime, and it tightens the obligations on everyone in the chain — including online sellers.

What it requires

• An EU economic operator. A product needs a responsible party established in the EU. For imported goods this is normally the importer; if the manufacturer is outside the EU and there is no importer, the manufacturer must appoint an authorised representative or EU Responsible Person.
• Traceability. The manufacturer's and importer's name, registered trade name or trademark, and contact address must appear on the product or its packaging, or in a document accompanying it.
• Technical documentation and risk assessment. A documented safety assessment must exist and be kept for ten years, available to market surveillance authorities on request.
• Safety information in the right language. Instructions, warnings and safety information must be in a language easily understood by consumers in the member state where the product is sold — for Germany, that means German.
• Online listings. Distance sellers must display the responsible person's name and contact details on the listing.
• Incident reporting and recall. Serious risks and accidents must be reported through the EU's Safety Business Gateway, and there must be an effective recall process.

Questions to ask your supplier

1. Can you provide a product risk assessment and the technical file for this item?
2. Will you supply the manufacturer's name, registered address and contact for the traceability labelling, and will you print it on the packaging?
3. Do you produce instructions and warnings in German, or only in English?
4. Can you hold the technical documentation for ten years and supply it within a reasonable deadline if the authority asks?
5. Do you have an existing EU Responsible Person or authorised representative arrangement, or do you need us to provide one?
6. If a safety issue is found after delivery, what is your reporting and recall process?

Part 2 — German EPR: Packaging and Beyond

Extended Producer Responsibility in Germany is not a single law. It is a set of product-specific regimes, and home and gift importers usually meet at least the first two.

Packaging (VerpackG)

Anyone who places sales packaging on the German market — including an importer bringing packaged goods into Germany — must:

• Register with the central agency (ZSVR) and receive a registration number, published in the LUCID register.
• Participate in a dual system (license) for the sales packaging, paying a fee based on material type and weight.
• Report packaging quantities — volumes placed on the market by material, through the LUCID register, in some cases with a declaration of completeness from a registered auditor.
• Offer take-back for transport and outer packaging, or ensure the buyer's system covers it.

Marketplaces and fulfilment service providers are also required to check that producers are registered, which is why an unregistered supplier quickly becomes the importer's problem. Registration and system participation are not optional, and they are audited.

Other German EPR regimes that catch home goods

• Electrical and electronic products (ElektroG): registration with the EAR authority, plus take-back and WEEE reporting obligations. Relevant for LED decorative items, clocks, lighting and anything with a plug, battery or cable.
• Batteries (BattG): separate registration and reporting for batteries placed on the market, including button cells in many decorative goods.
• Packaging made of composite materials: harder to recycle and typically licensed at a higher fee — worth designing out early.

Questions to ask your supplier

1. Can you provide the packaging weight and material breakdown per item — grams of paper, plastic, glass and metal, per unit and per carton?
2. Which parts of the packaging are sales packaging (going to the consumer) versus transport packaging?
3. Can you reduce, right-size or consolidate the packaging, and what would that change to the packaging weight?
4. Does the item contain a battery, LED, cable or electrical component that triggers separate registration?
5. Can you supply a bill of materials listing every material and surface treatment, so we can assess recyclability and licensing?
6. What is your packaging artwork layout, so we can add our EPR registration number and the responsible person details?

Part 3 — Category Certificates to Ask About

Beyond the horizontal rules, most home and gift categories have a specific regime. These are the ones importers most often ask a supplier to document:

• Food contact products (our kitchen and dining lines, tableware, glass, ceramics, storage containers): compliance with the EU food contact framework and the German LFGB, plus test reports for lead and cadmium migration for ceramic and glass items, and a declaration of conformity where applicable.
• Toys and child-appealing products: EN 71 (parts 1–3, mechanical, flammability, migration of elements) plus the Toy Safety Directive.
• Chemicals and materials: REACH compliance, including SVHC declaration, and SCIP notification if articles contain SVHCs above the threshold.
• Electrical items: RoHS and CE marking under the relevant directive, with the related test reports and declaration of conformity.
• Wood and paper: FSC or equivalent chain-of-custody certificate where a claim is made.
• Textiles and soft furnishing: fibre composition labelling and flammability information where applicable.
• Cosmetic-adjacent and aroma items (candles, diffusers): ingredient documentation and, depending on the product, additional labelling and safety data.

The practical question is not "do you have certificates" but "which certificate applies to this exact item, and can you send the PDF with the report number". Generic certificates issued for a different SKU, or a different material, are not evidence.

Part 4 — The Documents You Should Expect

A supplier set up for the European market can produce most of the following on request. If half of it is missing, that is a signal about the supplier, not only about the paperwork.

• Product risk assessment and technical file for the item.
• Test reports from an accredited laboratory, current and matched to the SKU.
• Declaration of Conformity where a directive applies, correctly signed and dated.
• Bill of materials with materials, finishes and treatments.
• Packaging weight and material data for EPR licensing and reporting.
• Labelling artwork showing the traceability block, warnings and instructions.
• For electrical items, documentation supporting EU Responsible Person and registration obligations.
• English and German versions of the documents the buyer needs.

Part 5 — Common Mistakes Importers Make

• Treating compliance as post-order paperwork. Documents that cannot be produced before production will delay the shipment, and clearance costs more than the certificate.
• Assuming the factory is the responsible operator. Under GPSR the EU-side party carries the obligation; the factory's opinion does not discharge it.
• Buying "the same" certificate for a new SKU. Certificates attach to materials and specifications, not to a product family name.
• Forgetting the packaging. VerpackG applies to the packaging itself — including the small plastic bag or hang tag — not only the product.
• Leaving the language question to arrival. German instructions and warnings have to exist before the goods are on the market.
• Not asking who pays for re-testing. If a batch fails, the cost and the timing belong in the terms, not in a later dispute.

The Bottom Line

GPSR and German EPR are not marketing topics — they are entry tickets. The importer holds the legal obligation, but the supplier holds the risk assessment, the test reports, the material data and the packaging figures that make compliance possible. Ask for them at the quoting stage, in writing, and treat a supplier's ability to produce them as a core selection criterion rather than a formality.

Ningbo Shihm Import and Export Co., Ltd. has supplied home décor, seasonal products and houseware to supermarkets, chain stores, importers and e-commerce sellers since 2008, and prepares compliance documentation with each order as a standard part of the process. If you are auditing a supplier for the European market, tell us what you need and we will tell you plainly which documents we can provide. You can also see the categories we produce across all categories and in home décor.

Related reading: what European buyers look for in a China supplier in 2026.