Key takeaways
- Since December 2024, every EU product listing must name a responsible person for product safety with reachable contact details.
- In 2026, Amazon enforces not just the responsible person field but also product labelling, safety warnings, and technical documentation.
- Listings can be suspended even if the responsible person field is filled, if labelling or documentation is missing or incomplete.
- National authorities now impose penalties for non-compliance, varying widely by EU member state since 2026.
- Sellers of electronics and toys are especially exposed if they cannot produce test reports or risk assessments on demand.
For most sellers, the GPSR responsible person for Amazon listings was a form field they filled once in late 2024 and have not thought about since. That was the right amount of effort for 2024. It is not the right amount for 2026.
The rule itself has not changed. Regulation (EU) 2023/988, the General Product Safety Regulation, has applied since December 13, 2024, and its text is published on EUR-Lex. What changed is what a compliance check consists of.
What the responsible person requirement is
Products sold to EU consumers need a named economic operator established in the EU who can be contacted about product safety, hold technical documentation, and act if something goes wrong. Their contact details have to be available in connection with the product.
One point sellers get wrong repeatedly: Amazon FBA is not your responsible person. Amazon storing and shipping the unit does not transfer the obligation. The seller, or a specialist appointed to act in that role, remains accountable regardless of who physically handles the goods.
What escalated in 2026
Through 2024 and 2025, marketplace enforcement was essentially a gate check. Is there a name and a contact in the responsible person field? If yes, the listing passed.
In 2026 the check widened. Platforms now look at product labelling, at whether safety and warning information is actually present on the listing, and at underlying documentation such as test reports and risk assessments when they request it.
The practical consequence is the part worth internalizing: a listing can be suspended or restricted while the responsible person field looks perfectly fine, because the gap that surfaced was in labelling or in documentation you could not produce on request.
The second consequence that was not there before
The other half of the change happens outside the marketplace.
National market surveillance authorities across member states have been running their own enforcement since 2025, and national penalty frameworks were finalized during 2026. So where non compliance in 2024 mostly meant a delisted product, in 2026 it can mean a delisted product and a national penalty, set by each member state rather than by Brussels. Amounts vary widely by country and are worth checking against your actual selling markets rather than assumed from a single figure.
Who is most exposed
Categories where a regulator or a platform can reasonably ask for a test report. Electronics is the clearest case: a seller who cannot produce the file on request is exposed even with immaculate listing metadata.
The same logic already played out in toys, where test report validity carries its own expiry clock. Documentation is not a thing you file once. It is a thing you have to be able to hand over on a short deadline, years after you sourced the product.
What to do about it
Run the check in the order a reviewer would.
First, confirm the responsible person named on your listings still exists, still consents to the role, and still answers at the contact details on file. Contracts lapse and people change jobs.
Second, look at the listing itself as a shopper would. Are the required warnings and safety information visible on the detail page, in the language of the marketplace? This is the layer that got added in 2026 and the one most catalogs fail.
Third, assemble the technical file per product, not per brand, and store it somewhere you can retrieve it in days. Test reports, risk assessment, declaration of conformity where the category needs one.
Amazon documents its compliance requirements in the Seller Central help hub, and the shift in how enforcement works has been documented independently by CMGM and FLEX Fulfillment, which agree on the direction if not on every national figure.
If you sell in the EU you are now inside two compliance systems at once, product safety and packaging rules under the EU framework. They are enforced by different bodies on different timetables, and neither one warns you before it reaches your listings.
Sources
Hey! I'm Amara
Press at SellerKey.co
☕ Espresso. Never a latte macchiato.
I cover Amazon fee and policy changes: what changed, when it applies and where Amazon published it.
