The situation
A range of private-label consumer products imported from outside the EU
A German homeware retailer buys knife sets, candles and cotton tea towels from factories in Asia and sells them under its own brand in its stores, its webshop and on two marketplaces. One marketplace has started blocking listings without responsible-person details. Purchasing asks whether the factory can simply be named instead.
Counsel has to work out which role the retailer holds for each product, what the regulation requires of that role, and what the listings must show. The hours go into the overlap: a retailer that imports, sells under its own brand and lists on marketplaces is several economic operators at once.
What the research has to settle
The rules behind the answer
- Your brand can make you the manufacturer
- Under the General Product Safety Regulation, a business that places a product on the market under its own name or trademark is treated as the manufacturer. It takes on the manufacturer’s duties, including the internal risk analysis and technical documentation.
- An EU operator must stand behind each product
- A consumer product can be placed on the EU market only if an economic operator established in the EU is responsible for it. Its name and contact details must accompany the product.
- Online listings must carry the details
- Distance sales must show the manufacturer’s name and postal and electronic address, the EU responsible person where the manufacturer is outside the EU, information to identify the product, and any warnings or safety information.
- Accidents and recalls have their own duties
- Manufacturers must report accidents caused by their products through the EU’s Safety Business Gateway, and the regulation sets rules on recalls and remedies for consumers.
How it runs in azta
From the question to the document
The question, as you would type it
German retailer importing knife sets, candles and tea towels from China and selling them under its own brand in stores, its webshop and on marketplaces. Under the GPSR, are we the manufacturer, the importer or both, what must our listings show, and can the Chinese factory be named as the responsible person?
You start with
A range of private-label consumer products imported from outside the EU
- 01
Describe the products and the chain
Give the products, who makes them, under whose brand they are sold and where. azta searches the GPSR, the Market Surveillance Regulation and the German implementing law.
Cited research· Free - 02
Read the definitions
Open the definitions of manufacturer, importer and responsible person in the reader, and check each against the retailer’s role.
Atlas statute reader - 03
Draft the duty list
Ask for an internal note listing each duty, which role it attaches to and an owner. Edit it in Canvas.
Canvas · Ask azta· Pro - 04
Reuse it for every new product
On Enterprise, save the note as a firm template so each new private-label product starts from the same checklist.
Firm templates· Enterprise You send
An internal note on the GPSR duties, who holds each and what listings must show
What you get
An internal note on the GPSR duties, who holds each and what listings must show
Internal note · draft
Private-label range: our duties under the GPSR
Our role. Because the products carry our brand, we are treated as their manufacturer. Because we bring them into the EU, we also import them. Our name, postal address and electronic address go on each product or its packaging, and we are the EU operator responsible for the range.
Before sale. For each product we need an internal risk analysis and technical documentation. Purchasing collects the factories’ test reports, but the documentation is ours and must be complete before a product is listed.
Listings. Every listing on our webshop and on the marketplaces shows our name and addresses, a product picture and identifier, and the warnings in German. The factory cannot be named as the responsible person because it is not established in the EU.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
14 minutes a month
At €120 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 32
- Capacity at your rate
- €3,888
- More product-safety duty notes a quarter
- 1.5
- Return on Pro
- 12×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
Want these numbers on your team’s real workload?
Book a demoWhat stays with you
- The technical risk analysis, which needs product specialists.
- Product-specific EU rules for goods outside the GPSR’s general scope.
- Assigning owners and approving the note.
Frequently asked questions
- Does the GPSR apply to CE-marked products?
- It covers the aspects and risks not covered by the specific EU legislation for that product. Ask about the product type and azta cites how the two regimes fit together.
- Does azta hold market-surveillance guidance?
- It holds the regulation and the national legislation. Authority guidance varies by country, and azta says what it cites.
- Can it read our supplier’s test reports?
- Yes. Upload them and ask what they cover. azta reads them and points to the passage it relied on. Judging whether the testing is adequate stays with your specialists.
