Recently we spoke to several sellers with the same story. They sell knitting patterns, sewing instructions or printable planners as PDFs on Etsy, nothing physical ever leaves their desk, and Etsy just told them they need an EU Responsible Person under the General Product Safety Regulation (GPSR). Some had never heard of the GPSR. Others thought it only covered physical goods.
The short answer: the GPSR does apply to digital products, according to both the law's own definition and the European Commission's guidance. Whether you need an EU Responsible Person depends on where you are based.
Why Etsy is asking digital sellers now
Etsy added a section for manufacturer and safety information to listings that can be bought from the EU, and digital listings now get it too. In its help article on the GPSR, Etsy states that the regulation applies to all types of products, both physical and digital, unless another safety law already covers them (source: Etsy Help).
For the sellers we spoke to, the email came without much explanation. So it is no surprise that they went looking for what it means. Etsy also gives a way out: you can choose to stop selling your digital items to buyers in the European Economic Area. For some shops that is the sensible choice.
Does GPSR apply to digital products?
The GPSR is Regulation (EU) 2023/988 and it has applied since 13 December 2024. Article 3(1) defines a product as "any item" supplied to consumers, whether for payment or not. Nowhere does the definition say the item has to be physical.
In November 2025 the European Commission published guidelines on how businesses should apply the GPSR. Section 2.1 of those Commission guidelines says the product definition covers any item, whether tangible or non-tangible or of a mixed nature, and names apps and software as examples (source: Commission Notice C/2025/6233).
Two caveats are worth knowing. The guidelines are the Commission's interpretation, not binding law; only the EU Court of Justice can settle the question for good. And they mention apps and software, not PDFs by name. Still, a downloadable pattern sold to consumers fits the wording of Article 3(1), the Commission reads the definition broadly, and Etsy has decided to apply it. In practice that settles it for anyone who wants to keep selling there.
Who needs an EU Responsible Person for a digital product
Article 16(1) of the GPSR says a product may only be placed on the EU market if there is an economic operator established in the EU who is responsible for it. For a digital product, the manufacturer is usually you: the designer who creates the file and sells it under your own name.
| Where you are based | What you need |
|---|---|
| In an EU country | No separate Responsible Person. You are the manufacturer in the EU, so your own name, postal address and email address go in the listing. |
| Outside the EU (for example the UK, the US, Canada or Australia) | An EU Responsible Person whose name, postal address and email address appear in the listing next to yours. |
This is the same rule that has applied to physical products since December 2024. If you also sell physical items, you may already have a Responsible Person, and the same appointment can cover your digital listings. We explain the role in more detail in our article on the EU Authorised Representative under GPSR, and the difference with the EC REP for medical devices in EU REP versus EC REP.
Selling digital products from outside the EU? We act as EU Responsible Person for more than 200 non-EU brands. See what is included on our EU Authorised Representative page.
Filling in GPSR manufacturer and safety information on Etsy
Article 19 of the GPSR lists what an online offer has to show. Etsy's new fields follow that list, which is why they look the same for physical and digital listings:
- The manufacturer's name, postal address and email address.
- If the manufacturer is not established in the EU: the name, postal address and email address of the Responsible Person.
- Information that identifies the product, such as a picture and a product name or number.
- Any warning or safety information that belongs with the product.
For most PDFs the fourth point stays short. A pattern for a soft toy is a good example of where it does matter: the buyer will make the toy, so a note on safe materials and small parts belongs in the instructions themselves. Write it there, not only in the listing.
What a Responsible Person does for a PDF
The role sounds heavier than it is. Under Article 4(3) of the Market Surveillance Regulation, which the GPSR refers to, the Responsible Person keeps the product documentation available for the authorities, provides information when they ask for it, informs them of a risk it becomes aware of, and cooperates if something has to be corrected (source: Regulation (EU) 2019/1020).
For a downloadable pattern, the documentation is modest: a description of the product, the safety information you give buyers, and your contact details. The value of the Responsible Person is mainly that there is an address in the EU that authorities can contact. For a seller outside the EU, that address is exactly what Etsy is checking for.
Your two options as a non-EU seller
You can appoint an EU Responsible Person and keep selling to the EU as before. Or you can use Etsy's setting to stop selling your digital items to buyers in the European Economic Area. The second option costs nothing, but you lose every European buyer. For a shop where EU sales are a small share, that can be a reasonable trade. For most of the sellers who contacted us, Europe was a market they did not want to give up.
Checklist for digital sellers
- Check where you are based. EU sellers only need their own details in the listing.
- If you are outside the EU, decide whether to appoint a Responsible Person or to stop selling digital items to the EEA.
- Add the manufacturer details and, where needed, the Responsible Person details in Etsy's new section.
- Read through your files and add safety notes where a buyer could get hurt making or using what you describe.
- Keep a simple folder per product with the file, the listing text and the safety information.
New to the GPSR? Our free introduction course to GPSR covers the basics in under two hours.
Want this sorted quickly? Send us the link to your Etsy shop through our contact page and we will tell you what you need.
Sources
- Regulation (EU) 2023/988 on general product safety (GPSR), Articles 3(1), 16 and 19. EUR-Lex
- European Commission, Guidelines on the application of the EU general product safety legislative framework by businesses, C/2025/6233, 21 November 2025, section 2.1. EUR-Lex
- Regulation (EU) 2019/1020 on market surveillance, Article 4(3).
- Etsy Help, What is the General Product Safety Regulation (GPSR)? help.etsy.com
