GPSR distributor obligations: what they check and ask for

Distributor or importer: what your EU customer is in law

The GPSR, Regulation (EU) 2023/988, gives every company in the supply chain a role. A distributor, such as a wholesaler, retail chain or online shop, makes your product available on the EU market but is neither the manufacturer nor the importer (Article 3(11) of Regulation (EU) 2023/988 (opens in a new tab)). The importer is established in the EU and places a product from a third country on the EU market, that is, supplies it there for the first time (Article 3(7) and (10)).

The difference decides what your customer must check. An EU company that buys your goods outside the EU and brings them in is your importer, whatever the contract says, with the stricter duties of Article 11 GPSR (compared in Authorized Representative or importer).

Two edge cases: a reseller selling your product in packaging translated for its country, still under your name or trademark, can still be a distributor (Commission GPSR guidelines, section 3.1.4). One selling it under its own name or trademark counts as the manufacturer (Article 13(1); see private label).

GPSR distributor obligations: the checks before the first sale

For consumer products that no EU harmonization legislation covers, Article 12(1) GPSR sets a short list. Before selling, the distributor verifies that you and any importer have met these requirements:

1. 1.Product identifier: a type, batch or serial number or another element, visible and legible for consumers; where size or nature require it, on packaging or an accompanying document (Article 9(5)).
2. 2.Manufacturer details: your name, registered trade name or trade mark, postal and electronic address, on the product or, where not possible, on packaging or an accompanying document (Article 9(6)).
3. 3.Instructions and safety information in a language set by the member state where the product is sold (Article 9(7)); see language requirements.
4. 4.Importer details, if there is an importer: its name, postal and electronic address, without covering your label, and instructions in the right language (Article 11(3) and (4)).

While the goods are in its hands, the distributor keeps storage and transport from affecting safety or labels (Article 12(2)). If it has reason to believe the product does not comply, it must not sell it until conformity is restored (Article 12(3)). If it suspects that a product already sold is dangerous or non-compliant, it immediately informs you or the importer, ensures corrective measures are taken and that authorities are informed through the Safety Business Gateway, the Commission's reporting portal (Article 12(4)).

Accidents go to you without undue delay (Article 20(3)) and, if you are outside the EU, to your EU responsible person, the EU economic operator required by Article 16 GPSR, which ensures they are notified (guidelines, section 3.1.4; Article 20(4)). See reporting and recalls.

CE-marked products: Article R5 and the sector law

For products under EU harmonization legislation, such as the CE legislation for electrical equipment, radio equipment or toys, Articles 9 to 18 GPSR do not apply (Article 2(1) GPSR). Distributor duties then come from the sector act, for CE acts modeled on Article R5 of Decision No 768/2008/EC (opens in a new tab): due care, then a check that the product bears the CE marking, comes with the required documents and instructions, and carries an identifier and the manufacturer's and importer's details (for example Article 9(2) of the Low Voltage Directive 2014/35/EU). Articles 19 and 20 GPSR still apply.

The Declaration of Conformity must travel with the product only where the sector act says so (Blue Guide, section 3.4). The Radio Equipment Directive 2014/53/EU (RED) does: each unit ships with a copy or a simplified version (Article 10(9)), which distributors check (Article 13(2)). A proposal to replace the copy with a web address or code was still pending on 6 October 2026 (COM(2025) 503 (opens in a new tab)). The Low Voltage Directive has no such rule; manufacturer and importer keep the declaration (Articles 6(3) and 8(8)).

What your distributor will ask for, and what is practice

Supplier questionnaires are business practice. A distributor may use one for its checks and its internal product safety processes (Article 14 GPSR), but the content is its choice, not a GPSR list. Sort each item before you answer:

• Photos of label, packaging and instructions. Practice, backed by law: they show what Article 12(1) GPSR or Article R5 requires the distributor to verify. Send them.
• Data for online offers. Law, if the distributor sells online: Article 19 GPSR requires your name and addresses, your EU responsible person, a picture and type, and warnings in the local language.
• Your EU economic operator. Law: GPSR products need one (Article 16(1) GPSR), as do most CE products (Article 4 of Regulation (EU) 2019/1020 (opens in a new tab)). For products placed on the market after 9 December 2026, a distributor that cannot name an EU operator or its own supplier within one month of an injured person's request may itself be liable under national law implementing Article 8(3) of Directive (EU) 2024/2853 (see Product Liability Directive).
• A safety contact. Your own duty for GPSR products: keep other operators in the supply chain informed of safety issues you identify (Article 9(10) GPSR).
• Declaration of Conformity. Law for CE products whose sector act requires it to accompany the product; otherwise practice. None exists for GPSR-only products.
• Test reports and certificates. Practice. Test reports belong in your technical documentation (for GPSR products, Article 9(2)(a)); sharing one is your decision.

What a distributor does not need from you

Your technical documentation stays with you. Article 12(1) GPSR does not refer to it, unlike the importer's check in Article 11(1). For CE products, the Blue Guide is explicit: the distributor “is however not expected to be in possession of the relevant documentation”, but must be able to name you, the importer or its supplier (section 3.4). Keep it ready for an authority request; what belongs in it: technical documentation.

The GPSR requires no Declaration of Conformity and no certificate, and the CE marking goes only on products whose harmonization legislation provides for it (Article 30(2) of Regulation (EC) No 765/2008). For CE products, see who signs the EU Declaration of Conformity.

When your customer is the importer, the checks go further

Before placing your product on the market, an importer must ensure that it is safe and that you carried out the risk analysis and drew up the technical documentation (Article 11(1) with Article 9(2) GPSR; see risk assessment). It keeps a copy for 10 years (Article 11(6)) and adds its own contact details to the product (Article 11(3)). Under CE legislation, it checks conformity assessment, technical documentation and CE marking and keeps a copy of the declaration for 10 years (Article R4; for example Article 12(2) and (8) RED).

The Blue Guide calls it good practice for importers to refer to EU law in the supply contract and to secure access to the technical file, or your signed commitment to provide it to authorities on request (section 3.3, footnote 139). An importer that asks for this is not overreaching.

Practical example: a U.S. fitness brand and two German buyers

A U.S. maker of foldable weight benches, a consumer product covered only by the GPSR (the guidelines name gymnastic equipment, section 2.2), sells to a German sports wholesaler that buys in the U.S. and imports the goods. A German online shop buys from the wholesaler. Both send questionnaires:

The brand sends both the same label photos and instructions, and the technical documentation only to the wholesaler.

Common mistakes with distributor questionnaires

• Sending the full technical file to every reseller. Distributors do not need it; send labels, instructions and listing data.
• Issuing a “GPSR Declaration of Conformity” or adding CE. The declaration does not exist, and CE is prohibited on GPSR-only products.
• Different contact details on product, packaging and listings. Distributors check the product, buyers see the listing (Article 19 GPSR); keep one set of details.
• Relying on the distributor's check. It is formal; you remain responsible for a safe design and manufacture (Article 9(1) GPSR).

Conclusion: answer the law first, then the practice

GPSR distributor obligations are narrow. Answer what the law requires completely, treat the rest as practice and decide what you share. First, check whether your customer is a distributor or your importer. Your own duties are listed in our GPSR compliance checklist.

Representa supports this through Market Entry Strategy, including the documents distributors and importers ask for, and through compliance verification: we review your documentation, labels and packaging and confirm the result in a report. As your EU Authorized Representative or GPSR Responsible Person, we act within the agreed scope and mandate: our name and address go on your packaging, and we handle authority inquiries. You remain the manufacturer and responsible for your product.

Frequently asked questions