Do I need GPSR compliance if I sell direct to consumer in Europe? Yes — and the reasoning takes three minutes.

The scope question, answered by the regulation itself

Article 2 of Regulation (EU) 2023/988 defines the scope of the GPSR in one sentence: the regulation applies to all non-food consumer products that are either new, used, repaired or reconditioned, placed on the Union market. The scope is determined by the product, not by the seller.

“Placed on the Union market” is a legal term with a specific meaning under EU product legislation: it is the first making available of a product on the Union market, in the course of a commercial activity, whether in return for payment or free of charge. For a D2C brand with a Shopify store, each sale of a product to an EU consumer is a placing on the market. For a designer with an Instagram storefront, same answer. For an artisan selling at Maison&Objet to a collector who takes the piece home, same answer again.

The size of the business, the number of units sold per month, the revenue, the platform, the country of residence of the founder — none of these factors are in Article 2. They are not in the scope definition because the European Commission chose not to include them.

The exemptions that do exist (and why they probably do not cover you)

Article 2 lists explicit exemptions from the GPSR’s scope. The full list is short, and none of it covers typical D2C consumer products:

Nothing on that list covers ceramics, wooden furniture, leather goods, clothing, fashion accessories, stationery, non-electronic sports accessories, bags, footwear (non-PPE) or costume jewellery (without electronic components). If your product is not a medicine, a food, a plant, an antique or a funfair ride, the GPSR applies.

What “no size threshold” means in the FAQ from the Commission

The European Commission published a FAQ on the GPSR in December 2024 specifically to address the question that small brand founders kept asking: does this apply to me if I am a one-person business? The Commission’s position was unambiguous. Exceptions cannot be made based on the size of a business. A sole founder selling 20 lamps a month to EU customers has the same Article 9 technical file obligation as a multinational lighting manufacturer.

This is a deliberate policy choice, not an oversight. The legislators who drafted the GPSR were aware that it would capture small D2C brands. Their reasoning, stated in the regulation’s preamble, is that consumer safety cannot depend on the size of the seller — a dangerous lamp is dangerous regardless of whether the maker is a corporation or a sole trader, and the consumer’s right to a safe product is the same in both cases.

For the D2C founder, this means the question is not whether the regulation applies (it does), but how to comply at a cost that is proportionate to the business. GPSRCheck exists for that exact reason: €49 per product, no subscription, so that compliance does not consume the margin on a small line. The PDF you download is permanent.

What’s in the 6-page PDF

Every page is generated locally in your browser. Nothing is uploaded to our servers. The file is yours the moment you close the tab.

The technical file and the EU Responsible Person: two separate things

The GPSR has two distinct compliance layers for non-EU sellers, and vendors in this market often bundle them into one expensive annual contract. They don’t have to be bundled.

The industry standard is to bundle both layers into a single annual subscription of €199 to €2,000, which means you cannot leave the vendor without losing access to your own documentation. We decouple the two on purpose: you own the document, you pick the Responsible Person separately, and if you ever change provider, your files travel with you.

Enforcement reality — the timeline that built this market

Why GPSRCheck rather than a consultancy or an annual subscription?