GPSR, EPR & EU Product Compliance: What Every Amazon Seller Must Know in 2026

If you're selling on Amazon in Europe and you haven't heard of GPSR yet, you're about to have a bad time. Since December 2024, the EU's new product safety regulation has been actively enforced — and Amazon has been removing non-compliant listings without much warning.

Add EPR (Extended Producer Responsibility) obligations on top of that, plus CE marking requirements and a new packaging regulation coming in August 2026, and you've got a compliance landscape that can genuinely make your head spin.

I'm going to break this down into what actually matters for Amazon wholesale sellers, what it costs, and what deadlines you absolutely cannot miss.

GPSR: The Big One

GPSR stands for General Product Safety Regulation (EU 2023/988). It replaced the older General Product Safety Directive on December 13, 2024, and it applies to essentially all non-food consumer products sold in the EU. Clothing, electronics, home goods, accessories, toys, furniture — if a consumer buys it, GPSR covers it.

A few product categories are exempt: prescription medications, food and drinks, living plants and animals, and genuine antiques or collector's items. Everything else? GPSR applies.

For wholesale sellers buying from EU-based distributors, GPSR mostly means making sure your product information on Amazon is complete. For sellers importing from outside the EU, it's a bigger deal because you need an EU Responsible Person.

What GPSR Actually Requires From You

There are four core obligations:

1. EU Responsible Person. If the product manufacturer is based outside the EU, someone inside the EU must be designated as the "Responsible Person." This person or company is the point of contact for EU authorities if there's a safety issue. If you're an EU-based seller buying from EU distributors, the manufacturer or importer typically already fills this role. If you're importing products from China, Turkey, or anywhere outside the EU, you either need to be the Responsible Person yourself or hire a service to act as one.

Cost for a Responsible Person service: roughly €400-500 one-time for standard products (clothing, home goods), or €650-2,000/year through premium providers. Budget providers start around €200/year. If you're a small seller importing a handful of products, expect to pay somewhere in the €400-800 range.

2. Product labeling and traceability. Products must have identifiers — type numbers, batch numbers, or serial numbers — so they can be tracked. The manufacturer's name and contact details must be on the product or packaging. This is almost always already handled by the manufacturer if you're buying branded wholesale products.

3. Technical documentation. You need to maintain declarations of conformity, risk assessments, and test reports. Amazon can request these at any time. Again, if you're buying from legitimate EU distributors, they should provide these. Ask for them upfront and keep them on file.

4. Amazon listing requirements. Your product listings must show: the manufacturer's name, their registered trade name or trademark, their postal and electronic address, and if the manufacturer isn't in the EU — the Responsible Person's name, postal address, and email. Product safety information and warnings must be in the local language of each marketplace.

How to Submit GPSR Info on Amazon

In Seller Central, go to Account Health > Policy Compliance (Amazon migrated everything there in May 2025). Look for any "GPSR: Responsible Person Contact Information" flags. Click "Submit information," add the Responsible Person's details (name, postal address, email), and save.

Important: you must do this separately for each EU marketplace — Germany, France, Italy, Spain, Netherlands, Poland, Sweden, Belgium. Same information, but submitted individually per marketplace.

What Happens If You Don't Comply

Amazon has been removing non-compliant listings since December 2024. Consequences escalate: first your listing gets deactivated, then suppressed, then you get account health flags. Repeated non-compliance can lead to account suspension.

Beyond Amazon, EU member states can impose their own fines. The GPSR framework allows penalties of up to €2 million or 5% of annual turnover (whichever is higher). Germany's draft implementing law — expected to take effect in early 2026 — proposes fines of up to €10,000 for minor violations (like missing contact details on packaging) and up to €100,000 for serious offences.

Generic appeals don't work anymore. If your listing gets deactivated for GPSR non-compliance, you need to submit specific documentation: valid EU Responsible Person details, declarations of conformity, and relevant test reports.

EPR: The Country-by-Country Headache

EPR (Extended Producer Responsibility) is a separate set of obligations that makes producers financially responsible for the end-of-life management of their products and packaging. Think recycling fees. Every EU country implements this differently, which is what makes it so annoying.

If you sell products in an EU country, you're considered a "producer" and need to register with that country's EPR systems and pay eco-contributions.

Germany

Packaging (VerpackG / LUCID): Register for free at the LUCID packaging register, then contract with a dual system provider (like Der Grune Punkt, Interseroh+, or BellandVision). Annual licenses start as low as €39-99/year depending on your packaging volume. Fees are calculated based on packaging material type and quantity.

Electronics (ElektroG / Stiftung EAR): If you sell any electrical or electronic products, you must register with Stiftung EAR before placing products on the German market. Basic annual fees start at €175/year, though full compliance through a service provider can run €860-1,200 per product category. You also need an insolvency-proof guarantee for B2C electronics — this can be a substantial cost for new sellers.

France

France has EPR across a staggering 19 categories. The main ones for Amazon sellers:

Packaging (CITEO): Registration fee around €50. Eco-fees depend on packaging composition and weight. Starting January 2026, eco-modulation kicks in — environmentally friendly packaging gets lower fees, while hard-to-recycle materials cost more. Aluminum packaging: €186.50 per tonne.

Textiles (Refashion): If you sell clothing or textiles, you need to register with Refashion. Eco-fees are roughly €0.01-0.06 per garment, depending on eco-modulation criteria.

Italy (CONAI)

Registration with CONAI is mandatory for any business placing packaged goods on the Italian market. Deadlines: RAEE (electronics waste) registration by December 31, 2025, and packaging/batteries registration by March 30, 2026.

Spain (Ecoembes)

Packaging EPR has been in force since January 2023. Since October 2024, it also covers tobacco products with disposable plastic filters and batteries. Commercial and industrial packaging was added in January 2025.

Amazon's "Pay on Behalf" Service

If you don't enter your EPR registration numbers in time, Amazon automatically enrolls you in their "Pay on Behalf" program. They pay the EPR fees for you but charge a service fee on top.

From January 1, 2026, this has been simplified to a flat €25 per EPR category per year (plus the actual eco-contribution fees). Not terrible for small sellers who don't want to deal with registrations in every country, but doing it yourself is cheaper if you sell enough volume to justify the admin time.

Key EPR Deadlines

December 31, 2025: WEEE (electronics) EPR numbers mandatory on Amazon.
March 31, 2026: EPR numbers mandatory for packaging, batteries, tires, oils, and polyethylene.
August 12, 2026: Under the new PPWR, all non-EU sellers need an Authorized Representative in each country where they sell.

CE Marking: Still Non-Negotiable

CE marking (Conformité Européenne) has been around for decades, but Amazon is getting stricter about enforcing it. Products that require CE marking but don't have it get immediately removed — and in many cases, permanently.

Products requiring CE marking include: toys, electronics, personal protective equipment, machinery, medical devices, construction products, gas appliances, pressure equipment, and radio equipment (phones, WiFi devices, Bluetooth speakers).

The good news for wholesale sellers: if you're buying branded products from EU distributors, CE marking should already be on the product. The manufacturer is responsible for obtaining CE certification and applying the mark. Your job is to verify it's there and keep the Declaration of Conformity on file.

Where it gets tricky: Amazon increasingly requires test reports from Amazon-approved laboratories, even for products with existing CE marking. In some cases, test data is transmitted directly from the lab to Amazon. Safety testing is also increasingly required on a recurring basis. So even if a product passed testing three years ago, Amazon might ask for updated reports.

If you're asked to provide CE documentation and your supplier can't or won't provide it, that's a serious red flag about the legitimacy of the product. Don't sell it.

New EU Toy Safety Regulation

The new EU Toy Safety Regulation (EU 2025/2509) entered into force on January 1, 2026, though full application isn't until August 2030. Key changes include stricter chemical safety requirements (banning CMR substances, endocrine disruptors, respiratory sensitizers), eventual Digital Product Passport requirements for all toys, and new obligations for online marketplaces to verify CE marking on toy listings.

If you sell toys: start paying attention now even though the transition period runs until 2030. Manufacturers will begin updating their compliance before the deadline, and Amazon may start enforcing some requirements early.

EORI: Simple but Required

EORI (Economic Operator Registration and Identification) is your customs identification number for importing goods into the EU. If you buy wholesale from EU distributors and never import from outside the EU, you might not need this immediately. But if you ever import products from non-EU countries, it's mandatory.

The good news: EORI registration is free and relatively quick. Apply through the national customs authority of the country where you first plan to import. Processing takes 1-3 business days in most EU countries (Germany and France can take up to 2 weeks). You get one EORI number that works across all EU member states.

UK sellers post-Brexit need two EORI numbers: a GB EORI for UK imports and a separate EU EORI for EU imports.

The New Packaging Regulation (PPWR) — Coming August 2026

The Packaging and Packaging Waste Regulation (EU 2025/40) takes full effect on August 12, 2026, and adds new requirements that directly affect Amazon sellers:

The 40% empty space rule: Your product packaging (including shipping boxes) must not have more than 40% empty space of total package volume, unless technically unavoidable. This affects how you pack FBA shipments and how the products you sell are packaged.

Material efficiency requirements: All packaging, including e-commerce parcels, must meet new standards for recyclability and material use.

Authorized Representative: Non-EU sellers shipping directly to EU consumers must appoint an Authorized Representative in the EU. Online marketplaces (including Amazon) are explicitly responsible for verifying seller packaging registration.

By 2030, there are even stricter requirements coming: 30-65% recycled content required for plastic packaging (varies by category), and online sellers must offer a reusable shipping option at checkout.

Coming Soon: Digital Product Passports

Starting July 2026, the EU will establish a central digital registry for Digital Product Passports (DPPs). The first mandatory DPPs will be for batteries (February 2027), followed by textiles, furniture, tires, and footwear (mid-2027).

DPPs will require product identifiers, material composition, environmental data (carbon footprint, durability, recyclability), all accessible via a QR code or similar data carrier. Products in covered categories won't be allowed into the EU market without one.

For wholesale sellers, this mostly impacts your suppliers — they'll need to create the DPPs. But you'll need to verify they exist and ensure the data carriers are on the products you sell.

Compliance Costs: What Does All This Actually Cost?

Let's put real numbers on this. Here's what a typical wholesale seller operating on Amazon Germany, France, and Italy might pay annually:

GPSR compliance: If buying from EU distributors — effectively free, since your suppliers handle the Responsible Person role and provide documentation. If importing from outside the EU: €400-800/year for a Responsible Person service, plus possible testing costs of €200-1,000 per product depending on category.

EPR - Germany packaging (LUCID): €39-99/year for registration and dual system contract. This is the cheapest and most critical one to set up first.

EPR - France packaging (CITEO): ~€50 registration plus eco-fees based on volume. A small seller might pay €100-300/year total.

EPR - Italy packaging (CONAI): Registration plus contribution fees based on packaging material. Similar range to France for small sellers.

EPR - Electronics (if applicable): Germany Stiftung EAR: €175+/year. Through a service provider: €860-1,200 per product category. This is a significant cost and worth calculating whether your electronics margins can absorb it.

CE marking verification: Free if your products already have proper CE marking (which they should from EU distributors). If you need new testing: €500-5,000 per product depending on category complexity.

EORI: Free.

Amazon Pay on Behalf (if you skip manual registration): €25/EPR category/year per country, plus the actual eco-fees.

Total for a typical small wholesale seller on 3 EU marketplaces: roughly €300-800/year for full compliance. That's less than a month's subscription to most Amazon seller tools. Yet non-compliance can cost you your entire account.

The Wholesale Seller Advantage

Here's something that rarely gets mentioned in compliance articles: wholesale sellers have it easier than private label sellers when it comes to EU compliance.

When you buy branded products from legitimate EU distributors, most compliance obligations fall on the manufacturer and the distributor, not on you. The manufacturer handles CE marking, creates the Declaration of Conformity, manages the EU Responsible Person designation, and ensures product labeling is correct. Your distributor should be able to provide all the documentation you need for Amazon.

Compare this to a private label seller who imports products from China: they need to arrange CE testing, hire a Responsible Person, create their own Declarations of Conformity, ensure labeling in every EU language, and manage EPR registrations for each product category in each country. The compliance burden is massive.

As a wholesale seller, your main responsibilities are: verifying that the compliance documentation exists (don't just assume — ask), keeping copies of everything on file, entering the required information in Seller Central, and registering for EPR in the countries where you sell.

The key question to ask every new supplier: "Can you provide the Declaration of Conformity and CE documentation for these products?" If they can't or won't, either the products aren't properly compliant or the supplier isn't organized enough to support you if Amazon asks questions. Either way, that's a red flag.

Important Dates: Your 2026 Compliance Calendar

Print this out, stick it on your wall, set calendar reminders — whatever works. Miss these and you'll have problems.

Already in effect: GPSR enforcement (since December 13, 2024). Amazon actively removing non-compliant listings.

March 31, 2026: EPR numbers mandatory on Amazon for packaging, batteries, tires, oils, and polyethylene. If you sell in these categories and don't have your EPR numbers submitted, your listings may be suppressed.

April 28, 2026: New compliance requirements for laptops take effect.

July 2026: EU Digital Product Passport central registry goes live.

August 12, 2026: New Packaging Regulation (PPWR) takes full effect. The 40% empty space rule applies. Non-EU sellers must have an Authorized Representative.

February 2027: Battery Passport becomes mandatory for all industrial and EV batteries.

Mid-2027: Digital Product Passports mandatory for textiles, furniture, tires, and footwear.

If you're a wholesale seller of standard consumer goods (not electronics, not batteries, not textiles), the March 31, 2026 and August 12, 2026 dates are your most critical near-term deadlines.

Practical Compliance Checklist for Wholesale Sellers

If you're selling branded products from EU-based distributors (which is most wholesale sellers), your compliance burden is lighter than you might think:

GPSR: Make sure your Amazon listings have complete manufacturer information and Responsible Person details. Ask your distributor for Declarations of Conformity for the products you buy. Submit GPSR info in Seller Central for each marketplace.

EPR: Register in each country where you sell. For packaging, Germany's LUCID is the most critical (and cheapest to set up). France is the most complex with 19 categories. If the admin overwhelms you, let Amazon's Pay on Behalf handle it for €25/category/year.

CE marking: Verify CE marks on every product that requires them. Keep technical documentation on file. If Amazon asks for compliance docs, get them from your supplier immediately.

EORI: Get one if you import from outside the EU. Free and takes a few days.

The cost of compliance is real but manageable: €100-500/year for EPR registrations across the main countries, plus time to submit the right paperwork. The cost of non-compliance — suspended listings, account health hits, and potential fines of up to €100,000 — makes it a no-brainer.

Frequently Asked Questions

What is GPSR and does it affect Amazon wholesale sellers?

GPSR (General Product Safety Regulation) is an EU regulation effective since December 13, 2024 that requires all products sold in the EU to have a designated EU Responsible Person with a physical EU address on the product or packaging. Yes, it affects wholesale sellers — you must ensure your products have compliant GPSR information or Amazon may deactivate your listings.

Do I need an EU Responsible Person to sell on Amazon Europe?

Yes, every product sold on Amazon EU must have an EU-based Responsible Person. For wholesale sellers buying from EU-based brands, the manufacturer or brand owner is usually the Responsible Person. For products imported from outside the EU, you may need to designate one yourself. EU RP services cost EUR 100-500/year depending on the number of products.

How much does EPR registration cost per country?

EPR registration costs vary by country: Germany (LUCID/Zentrale Stelle) is free to register but costs EUR 50-200/year for packaging fees. France (Citeo) costs EUR 100-300/year. Spain (Ecoembes) costs EUR 80-200/year. Italy (CONAI) costs EUR 50-150/year. Most wholesale sellers spend EUR 500-1,500/year total across all required EU countries.

What happens if I am not GPSR compliant on Amazon?

Amazon has been actively enforcing GPSR since early 2025. Non-compliant listings are deactivated without warning. Repeated violations can lead to account suspension. You may also face fines from EU market surveillance authorities of up to EUR 100,000 or more depending on the member state.

What is the difference between GPSR and EPR?

GPSR deals with product safety — ensuring every product has a designated EU Responsible Person and proper safety documentation. EPR (Extended Producer Responsibility) deals with environmental compliance — requiring you to register and pay fees for packaging waste, electronics (WEEE), and batteries in each EU country where you sell. Both are mandatory but cover different aspects.

Do wholesale sellers need GPSR compliance or only private label sellers?

Both need GPSR compliance. The advantage for wholesale sellers is that the brand or manufacturer has usually already designated an EU Responsible Person. You just need to verify this information exists on the product and upload it to Amazon Seller Central. Private label sellers bear the full burden of becoming the RP themselves.