The EU’s General Product Safety Regulation (GPSR) took effect on December 13, 2024, and most compliance guides written since then cover the same basics: appoint an EU Responsible Person, update your labeling, keep a technical file. If your product or your client’s product cleared that bar back in 2024 or 2025, it’s easy to assume the compliance work is done.
It isn’t. 2026 is the year GPSR stopped being a documentation exercise and became an enforcement regime — and the shift matters most for exporters and factories who treated the Responsible Person requirement as a one-time box to check.
What Actually Changed This Year
GPSR is a regulation, meaning it applies uniformly across the EU without needing each country to write its own version. But the penalties for violating it are set at the national level, and those national penalty frameworks are only now being finalized — roughly a year and a half after the regulation itself came into force.
A few examples reported by legal and compliance trackers in the first half of 2026 give a sense of scale:
- Italy’s draft penalty decree, nearing final approval in early 2026, proposes fines up to €150,000 and criminal sanctions for the most severe violations — such as knowingly placing a dangerous product on the market.
- The Czech Republic’s framework sets fines up to roughly CZK 5 million for online listing deficiencies, up to CZK 20 million for distributor violations, and up to CZK 50 million for manufacturers or importers who place unsafe products on the market.
- Bulgaria amended its Consumer Protection Act in February 2026 to add its own penalty tier.
This is worth noting because it changes the risk calculus. In 2024–2025, the practical consequence of GPSR non-compliance was mostly a delisted product on a marketplace. In 2026, it’s a delisted product plus a national fine that varies significantly depending on which EU country’s market surveillance authority catches it first.
Platform Enforcement Has Also Moved Past Phase One
When Amazon and other marketplaces first rolled out GPSR compliance fields in late 2024, enforcement focused almost entirely on one thing: did the listing have a valid EU Responsible Person on file? That was the easiest violation to detect automatically, so it was the first one platforms went after.
Industry reporting from early-to-mid 2026 describes platforms expanding checks to labeling requirements, the presence of safety and warning information on the listing itself, and — for some categories — requests for the underlying documentation (risk assessments, technical files) rather than just the Responsible Person’s contact details.
For a factory or trading company that appointed a Responsible Person in 2024 and hasn’t touched the file since, this is the relevant question: does the product listing itself — not just the compliance dashboard — actually carry the manufacturer name, batch/serial identifier, and safety warnings in the buyer’s language? That’s a separate check from “do we have a Responsible Person,” and it’s the check platforms are increasingly running.
A Common Misconception Worth Correcting
A Responsible Person is not the same thing as compliance. The Responsible Person is one required contact point in the EU — an obligation, not a certification. Appointing one satisfies the requirement that a product’s listing not be hidden from EU buyers, but it does nothing on its own to establish that:
- the underlying risk assessment for the product exists and is current
- the labeling on the physical product (not just the online listing) meets GPSR’s language and identifier requirements
- the manufacturer information provided is accurate and traceable back through the actual supply chain, not just a nominal entity
Several EU legal trackers monitoring 2026 enforcement note that market surveillance authorities are increasingly using their expanded powers to demand this underlying documentation directly, rather than relying solely on marketplace-level checks. A Responsible Person listing that looks complete on Amazon’s compliance dashboard doesn’t guarantee the file behind it would hold up if a national authority asked for it.
What This Means in Practice for Suppliers
For manufacturers and trading companies exporting to the EU, or working with importers who do, three things are worth verifying now rather than waiting for a takedown notice:
- Confirm the Responsible Person arrangement is still active and correctly linked. Services set up quickly in 2024 to meet the original deadline sometimes lapse or change without the exporting factory being notified.
- Check whether product-level documentation exists, not just account-level compliance status. A risk assessment and technical file per product (or per product family) is the underlying requirement — the Responsible Person listing is downstream of it.
- Review physical labeling separately from online listing compliance. These are enforced somewhat independently, and a product that passes the online compliance check can still carry non-compliant physical labels.
There’s no publicly available data yet on how many China-based sellers or suppliers have been affected by 2026’s enforcement escalation specifically — that figure doesn’t appear to be tracked or published anywhere at this point. What is clear from the regulatory trackers is the direction: enforcement in 2026 is broader and better-resourced than in the regulation’s first year, and the assumption that a 2024 compliance setup is still sufficient is no longer safe.
For related background on how EU market surveillance identifies and acts on specific unsafe products once they’re flagged, see our Safety Gate case study on heavy metals in jewellery. For sellers weighing UK versus EU labeling requirements on the same product line, our comparison of UKCA and CE marking requirements covers where the two regimes diverge.