Compliance Checklist

GPSR (General Product Safety Regulation)
Automotive
Germany 🇩🇪

GPSR compliance for automotive accessories on Amazon Germany: distinction from E-mark approval, obligations for economic operators, costs and typical mistakes.

Overview

The General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, has been the central safety framework for automotive accessories and non-safety-critical automotive products on Amazon.de since December 13, 2024. Important: The GPSR covers general automotive accessories – phone holders, organizers, seat covers, floor mats, car care products, interior accessories. Safety-critical vehicle parts such as brake pads, tyres, child seats or lighting requiring E-mark approval are subject to separate EU type-approval regulations (ECE/UNECE regulations) and are NOT primarily regulated by the GPSR.

Does this apply to my product?

The GPSR applies to all non-type-approval automotive products sold to consumers on Amazon.de: car phone holders, organisers and storage, seat covers, floor mats (universal and custom-fit), car care products (cleaners, polishes, care products), sun shades and privacy screens, steering wheel covers, boot mats, charging cables and USB adapters (unless falling under RED/LVD directives), air fresheners, ice scrapers and snow brushes. NOT covered by the GPSR (but by ECE type-approval): brake pads, tyres, child seats, headlights/tail lights with E-mark, seat belts, airbag components.

Step-by-Step Guide

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Classify product category: GPSR vs. ECE type-approval

The first and most important step: check whether your automotive product falls under the GPSR or requires a separate ECE/E-mark. Wrong classification can have serious legal consequences.

Estimated time: 1-2 Tage

Product classified as GPSR-relevant or requiring type-approvalRequired

GPSR products: accessories with no impact on vehicle safety (phone holders, seat covers, floor mats, organisers, care products). ECE-required products: everything affecting vehicle safety (brakes, lighting, tyres, child seats) – these need E-mark approval under UNECE regulations. Grey area: roof boxes, tow bar accessories, LED interior lighting – seek legal advice if in doubt.

Own role as economic operator determinedRequired

Manufacturer: develops or has products made under own name. Importer: places products from outside the EU on the market. Distributor: resells without manufacturing/importing. Fulfilment service provider: stores and ships (Amazon FBA). Each role has specific GPSR obligations.

Designate Responsible Person and conduct risk assessment

The GPSR requires a Responsible Person in the EU (Art. 16) for non-EU manufacturers and a risk assessment that considers automotive-specific hazards.

Estimated time: 3-7 Tage

Responsible Person in the EU designated (Art. 16 GPSR)Required

Required when the manufacturer is based outside the EU and no EU importer is available. The Responsible Person must be stated on the product or packaging with contact details and must keep the technical documentation available.

Appointment agreement with the Responsible Person in the EU

Risk analysis with automotive-specific hazards completedRequired

Automotive-specific risks: distraction risk from phone holders restricting the field of view, slip risk from floor mats blocking pedals, chemical risks from car care products (fumes, skin contact), fire risk from sun shades/films under sun exposure, choking risk from small parts in car accessories in vehicles with children.

Written risk analysis evaluating all identified hazards

Relevant product standards and safety standards checkedRequired

Relevant standards depending on product type: EN 71 (if children are a possible user group), EN ISO 12100 (general safety of machinery for mechanical accessory parts), REACH Regulation for chemicals in care products, CLP Regulation for labelling of chemical products. Compliance with harmonised standards creates a presumption of conformity.

Create technical documentation and traceability

The GPSR requires technical documentation containing the complete safety evidence. This includes full traceability of the product.

Estimated time: 3-5 Tage

Technical documentation compiledRequired

Content: product description, material specifications, risk analysis, test reports (material testing, load tests), production controls, photos, user instructions. For car care products additionally: Safety Data Sheet (SDS), CLP-compliant labelling.

Technical documentation as a coherent dossier

Traceability ensured (batch number, product identification)Required

Each product must be uniquely identifiable: model designation, batch or serial number, manufacturer details. The information must be on the product, packaging or an accompanying document.

Apply labelling and consumer information

All mandatory information must be applied to the product or packaging. For the German market, safety instructions in German language are required.

Estimated time: 2-4 Tage

Contact details of manufacturer/Responsible Person on product or packagingRequired

Name, registered trade name or trademark, postal address and electronic contact (email, URL or phone). For importers: additionally importer details. A QR code on the packaging can link to a digital product information page.

Safety and usage instructions in German languageRequired

Particularly important for car accessories: mounting instructions for phone holders (do not mount in field of view), installation notes for floor mats (use securing hooks, check pedal clearance), warnings for chemical products (CLP pictograms, hazard statements H/P phrases), load limits for organisers and storage.

Safety instructions and user manual in German language

Warnings for foreseeable misuseRequired

Typical misuse in the automotive sector: floor mats without securing that slide under pedals, phone holders on windshield blocking field of view, car care chemicals used without gloves, sun shade not removed before driving.

Set up reporting obligations and corrective measures

The GPSR obliges all economic operators to inform authorities about safety defects and take corrective measures.

Estimated time: 1-2 Tage

Internal complaints register and recall procedure establishedRequired

Maintain a register of customer complaints, returns due to safety concerns and defective products. Define a process for recalls and market withdrawals. Report to BAuA via the EU Safety Business Gateway for serious risks.

Contact point for authorities and consumers establishedRequired

Set up an accessible contact point (email or phone) for product safety inquiries from authorities and consumers. This must be stated in the technical documentation and on the product/packaging.

Complete Amazon listing with GPSR mandatory fields

Since December 2024, GPSR mandatory information must be entered in Amazon Seller Central. Missing data can lead to listing suspension.

Estimated time: 1-2 Tage

GPSR mandatory fields in Amazon Seller Central completedRequired

Mandatory information in Seller Central: manufacturer name and address, name and address of the Responsible Person in the EU (if manufacturer outside EU), email or website for contact, warnings and product safety information.

Compliance documents prepared for AmazonRequired

Keep technical documentation, test reports and Safety Data Sheets if applicable ready. Amazon may request these during compliance checks. Upload relevant documents to Seller Central.

Technical documentation + test reports as PDF in Seller Central

Common Mistakes to Avoid

Confusing general car accessories with safety-critical vehicle parts

Consequence: If a product is incorrectly treated only under GPSR when it needs ECE type-approval (e.g. LED replacement bulbs for headlights), fines, confiscation and even criminal consequences are possible. Conversely, unnecessary E-mark certification leads to avoidable costs of 10,000+ EUR.

Prevention: Check above all whether your product affects vehicle safety. Floor mats, phone holders, seat covers = GPSR. Brake pads, headlights, tyres = ECE. If in doubt: seek advice from the KBA or specialised compliance service provider.

Floor mats sold without securing system and warning

Consequence: Unsecured floor mats can slide under pedals and cause accidents. This is a well-known and serious safety risk. Floor mat recalls are not uncommon – even car manufacturers have had to recall floor mats.

Prevention: Equip floor mats with securing hooks or anti-slip coating. Add clear warnings: mat must be secured, check pedal clearance after installation, do not stack multiple mats.

No Responsible Person in the EU for non-EU manufacturers

Consequence: Without a Responsible Person per Art. 16 GPSR, selling on Amazon.de is not permitted since December 2024. Amazon can suspend the listing, market surveillance authorities can prohibit distribution and impose fines.

Prevention: Designate a Responsible Person based in the EU in good time. This can be your EU importer, an authorised representative or a specialised GPSR service provider.

Forgetting CLP labelling for car care products

Consequence: Car care products (cleaners, polishes, de-icers) are often chemical mixtures falling under the CLP Regulation (EC) No 1272/2008. Missing hazard pictograms, H and P statements and signal words violate EU chemical law and can lead to listing suspensions on Amazon.

Prevention: Create a Safety Data Sheet (SDS) for each chemical car care product and label the packaging CLP-compliant with pictograms, signal word, H and P statements in German language.

Frequently Asked Questions

Q1Does my car accessory need an E-mark or is the GPSR sufficient?

It depends on whether the product affects vehicle safety. General accessories like phone holders, seat covers, floor mats, organisers and care products fall under the GPSR – no E-mark needed. Safety-critical parts like brake pads, headlights, tyres and child seats require ECE type-approval with E-mark. In the grey area (e.g. LED interior lighting, roof racks): check the ECE regulation list at the KBA or seek advice.

Q2Do car care products (cleaners, polishes) also fall under the GPSR?

Yes, car care products fall under the GPSR as general consumer products. Additionally, they must also comply with the CLP Regulation (chemical substance labelling) and the REACH Regulation (chemical registration). This means: GPSR obligations (Responsible Person, traceability) PLUS CLP-compliant labelling with hazard pictograms and H/P statements PLUS a Safety Data Sheet (SDS). The CLP requirements come on top.

Q3Do I need separate GPSR documentation for each floor mat variant (different car models)?

Not necessarily. If the floor mats are made from the same material, manufactured using the same process and have the same safety properties, you can create a framework documentation covering all variants. However, the risk analysis should check per vehicle model whether specific risks exist (e.g. different securing systems). Batch numbers and traceability must be individually ensured for each variant.

Q4What happens if Amazon suspends my car accessory listing due to missing GPSR data?

First complete all missing GPSR mandatory fields in Seller Central: manufacturer data, Responsible Person, contact information and warnings. Upload the technical documentation as PDF. Then create a Plan of Action and submit it to Amazon. Typically the listing is reactivated within a few days after complete data entry. Also check all other listings for completeness to avoid further suspensions.

GPSR (General Product Safety Regulation)AutomotiveGermany 🇩🇪

Classify product category: GPSR vs. ECE type-approval

Designate Responsible Person and conduct risk assessment

Create technical documentation and traceability

Apply labelling and consumer information

Set up reporting obligations and corrective measures

Complete Amazon listing with GPSR mandatory fields

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