GPSR for Importers from Asia: What EU Importers Actually Need to Do

If you are an EU-based business importing consumer goods from Asia, the General Product Safety Regulation (GPSR) changed the game on 13 December 2024. Before that date, most importers relied on their Chinese or Vietnamese suppliers to "handle the compliance side". After that date, you are legally responsible under EU law, whether your supplier helps or not. In practice we now see two groups of importers: those who prepared and can prove it, and those who got a documentation request from the NVWA and could not answer within the deadline.

This article is written for the second group, or for anyone who wants to make sure they never end up in it. We are Westwood Sourcing, based in Breda, and we have been sourcing from Asia for EU clients since 2019. Since GPSR took effect, we have helped 40+ EU importers restructure their supplier processes to be genuinely compliant, not just paper-compliant.

What GPSR is, in one paragraph

The General Product Safety Regulation (Regulation (EU) 2023/988) applies to almost all non-food consumer products placed on the EU market. It replaced the old General Product Safety Directive on 13 December 2024. Its core requirement is that every product must be safe, traceable and supported by adequate documentation, and that a named EU-based economic operator is legally responsible for compliance (source: EUR-Lex, Regulation (EU) 2023/988). For a fuller explainer, see our articles on EU REP vs EC REP and what an EU Authorised Representative for GPSR actually does.

Why EU importers face different obligations than non-EU sellers

This is where a lot of confusion sits. If you are a company registered in the Netherlands, Belgium, Germany or another EU country and you import from Asia, you do not need an EU Authorised Representative. You are the responsible economic operator yourself. That is a good thing (no extra 150 EUR annual fee) and a bad thing (all the compliance duties land on your desk).

Non-EU sellers (US, UK, China-based e-commerce brands) need to appoint someone in the EU. That is what we covered in blog 2. But if you are the EU importer bringing goods in yourself, you take on the responsibilities directly under Article 4 of the GPSR (source: EUR-Lex, Regulation (EU) 2023/988, Article 4). Your Chinese supplier is not your responsible economic operator, no matter what your Alibaba contact says.

Concretely, this means you must verify safety documentation before placing goods on the market, keep a technical file for 10 years, ensure traceability, place your name and contact details on the product or packaging, and cooperate with market surveillance authorities if they knock.

The five things GPSR requires from you as EU importer

We work through this list with every new sourcing client. It is the shortest path to compliance without paying for things you do not need.

1. Verified product safety documentation before goods leave the factory. Your supplier must provide test reports proving the product meets the relevant EN harmonised standards (for toys that is EN 71, for electricals often EN 60335, for textiles the REACH Annex XVII substance restrictions). You need this before shipment, not after. Once the container is in Rotterdam and the NVWA asks, "too late" is not a defence.
2. A complete technical file, kept for 10 years. The technical file is your compliance dossier per product. It includes the specifications, the risk assessment, the test reports, the Declaration of Conformity (where applicable), the labelling and packaging design, and the history of any product changes. Most importers we onboard did not have one at all when they came to us.
3. Product traceability throughout the supply chain. Every product needs an identifier (batch number, serial number, model number) that lets you trace it back to a specific production run and, if needed, recall it. If a batch has a defect, you must be able to say "affected units are batch code XYZ produced in week 34". If you cannot, you may have to recall everything.
4. EU importer contact details on the product or packaging. Your business name and a way to contact you must be clearly visible. This is what allows consumers and authorities to reach the responsible party in the EU. Your Chinese factory's address is not enough.
5. Cooperation with EU market surveillance authorities. If the NVWA (in the Netherlands), the German BAuA, or any other market surveillance body requests documentation or samples, you must respond within their timeframe (usually a few days to a few weeks depending on urgency). If the product is potentially unsafe, you must take corrective action, which can mean a full recall.

How to check whether your Asian supplier is GPSR-ready

Not every Chinese or Vietnamese factory is at the same level. Some large operations have full EN-standard test reports on demand, some smaller factories have never heard of GPSR. Here is what to check, in the order we run it.

Ask for the exact test report, by EN standard number. Do not accept "we have all the necessary certifications". Ask for the EN 71 report if it is a toy, the EN 60335 report if it is a household electrical, the REACH Annex XVII test if it is textiles or furniture. The report must be issued by a recognised testing laboratory, dated within the last 3 years, and matched to the specific product model you are ordering.

Verify the testing laboratory. In our experience about 15% of Chinese suppliers submit reports from unaccredited labs or labs that do not exist. Cross-check the lab name on ILAC MRA (International Laboratory Accreditation Cooperation) or your country's equivalent. If the lab is not findable, the report is worthless.

Check the Declaration of Conformity (where required). For products that fall under CE marking directives (electricals, toys, machinery, PPE, etc.), a Declaration of Conformity must be drawn up. Ask for a sample DoC on your product. Many factories will draft one for you if you push, some will not, and that tells you something about their compliance maturity.

Do a physical sample check against the report. The report says "battery capacity 2000mAh, plastic Type ABS". Check that the actual product matches. We have seen too many cases where the report is real but corresponds to a different product than what actually gets shipped.

Ask about their process for compliance updates. GPSR is not the last regulation coming. PPWR applies from 12 August 2026 and we set out what that means in practice separately. EPR programmes vary per member state. A supplier who cannot explain how they handle regulatory updates will leave you exposed to the next round.

A real case: Dutch electronics importer, avoided a recall

One of our sourcing clients, a Dutch importer of USB-C chargers, came to us in October 2024 with an order they were about to place at a factory in Shenzhen. The factory had provided a test report that "looked professional", 40 pages, English, with photos and technical measurements. We reviewed it as part of the sourcing process.

Two problems came out within an hour. First, the report was from a lab that was not on the ILAC MRA register, which we found after 15 minutes of searching. Second, the report covered a different product variant than what the client was actually ordering, the report was for the 20W model but the order was for the 30W model.

We flagged both to the factory. The factory admitted the discrepancy, sourced a proper EN 60950-1 test at a Bureau Veritas facility in Shenzhen (cost the client 380 EUR, added two weeks), and re-issued the report on the correct product. Six months later, the NVWA did a spot check on one of the client's shipments after a competitor's similar product was flagged for overheating. The client sent us the request, we forwarded the proper documentation, and the check closed the same day.

Without the initial catch, the client would have imported 3,000 units against a false report, and either faced a costly recall or a market withdrawal. The 380 EUR upfront saved a five-figure problem downstream.

What to do if you already imported without proper GPSR documentation

This is a common situation. You have goods in your warehouse, you are already selling them, and you now realise the documentation is thin. Do not panic and do not stop selling immediately (that creates its own problems). Do this instead.

1. Do a risk-based inventory. Which of your product lines are highest risk (products that go on skin, toys for children under 3, anything electrical)? Prioritise documentation for those first.
2. Contact your supplier for the missing documentation. Ask for the test reports, DoC, and technical specifications for each product. Give them a reasonable deadline (2 to 3 weeks). If they cannot deliver, that itself is a compliance signal.
3. Where you cannot get documentation, commission independent testing. In the EU or at a certified lab in Asia (SGS, Bureau Veritas, TUV, Intertek). For a typical consumer electronics product this costs 250 to 800 EUR per SKU. Not cheap, but far cheaper than an authority-mandated recall.
4. Update your labelling. If your name and EU contact details are not on the product or packaging, add stickers as an interim measure and update the packaging design for the next production run.
5. Document what you did and when. If an authority ever questions you, showing that you took reasonable corrective action once you knew is materially better than showing nothing.

When you need an EU Authorised Representative anyway?

Two edge cases where EU importers still need or benefit from an EU AR relationship.

You act as importer for some products but not for others. For products that you drop-ship without ever taking physical import (goods flow directly from the Chinese factory to the EU customer via Amazon FBA), you might not qualify as importer under the strict legal definition. In that grey zone, having an EU AR as a fallback is a low-cost safety net.

You import for other resellers and want to shift the responsible-operator role. If you import into the EU but then sell in bulk to resellers who put the product under their own brand, the responsible economic operator role can move to them, which means they might need an EU AR. This is worth clarifying in your commercial contracts.

For most straightforward importers, however, you do not need an EU AR. You are the responsible party yourself.

Conclusion: your supplier is not your compliance department

GPSR shifted the accountability line firmly to the EU importer. Your Chinese, Vietnamese or Indian supplier can help you build the documentation, and a good one will, but the legal responsibility is yours. That means: verify test reports before shipment, keep a proper technical file per product, ensure traceability, put your EU contact details on the product, and respond fast if an authority asks questions.

The importers who prepared for this before December 2024 barely notice GPSR in their daily operations. The ones who did not prepare are the ones dealing with NVWA letters and marketplace suspensions. If you are in the second group, the good news is that catching up is finite work with a clear checklist.

Sources

• European Union. Regulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety (GPSR). EUR-Lex. eur-lex.europa.eu/eli/reg/2023/988
• European Commission. Product safety and compliance guidance. commission.europa.eu/business-economy-euro/product-safety-and-requirements_en
• Nederlandse Voedsel- en Warenautoriteit (NVWA). Productveiligheid. nvwa.nl/onderwerpen/productveiligheid
• International Laboratory Accreditation Cooperation (ILAC). Mutual Recognition Arrangement (MRA). ilac.org/ilac-mra-and-signatories
• European Commission. Safety Gate rapid alert system for dangerous non-food products. ec.europa.eu/safety-gate