Compliance Checklist

GPSR (General Product Safety Regulation)
Cleaning & Household
Germany 🇩🇪

Complete compliance checklist for the EU General Product Safety Regulation (GPSR, EU 2023/988) for cleaning and household products on the German market, including Detergents Regulation, CLP Regulation, and Biocidal Products Regulation.

Overview

The EU General Product Safety Regulation (EU) 2023/988 (GPSR) has been in effect since December 13, 2024, replacing the former Directive 2001/95/EC. For cleaning and household products on Amazon.de, manufacturers and importers must fulfill comprehensive requirements: designate an EU Responsible Person, create technical documentation, ensure CLP-compliant labeling with GHS hazard pictograms, and provide Safety Data Sheets in German. Additionally, the Detergents Regulation (EC) 648/2004 applies to detergents and cleaning products, and the Biocidal Products Regulation (EU) 528/2012 applies to disinfectants. Amazon.de requires specific product data and SDS uploads for hazardous materials (Hazmat) products.

Does this apply to my product?

This checklist applies to all cleaning and household products sold on Amazon.de, including: all-purpose cleaners, laundry detergents, dishwashing liquids, bathroom cleaners, glass cleaners, descalers, disinfectants, toilet cleaners, mold removers, oven cleaners, and household chemicals. Special attention is required for biocidal products (e.g., disinfectants, mold removers) and products containing hazardous substances under the CLP Regulation.

Step-by-Step Guide

Progress0/15 (0%)

Product Classification and Regulatory Analysis

Determine the exact regulatory classification of your cleaning product. Check whether it falls under the Detergents Regulation, the CLP Regulation, and/or the Biocidal Products Regulation. This classification determines all subsequent compliance requirements.

Estimated time: 1-2 weeks

Perform CLP classification and hazard assessmentRequired

Classify your product according to CLP Regulation (EC) 1272/2008. Determine hazard classes, hazard categories, H-statements (hazard statements), and P-statements (precautionary statements). Check the ECHA database for registered substances and use the Classification and Labelling Inventory (C&L Inventory).

CLP classification report with hazard classes and H-/P-statementsChemical safety report for all ingredients

Check biocidal product status (if applicable)Required

Check whether your product contains biocidal active substances (e.g., disinfectants, mold removers, antibacterial cleaners). Biocidal products require authorization under the Biocidal Products Regulation (EU) 528/2012. In Germany, BAuA (Federal Institute for Occupational Safety and Health) is the competent authority for biocide authorization.

Biocide authorization certificate from BAuA (if applicable)BAuA registration number for the biocidal product

Check Detergents Regulation complianceRequired

Determine whether your product falls under the Detergents Regulation (EC) 648/2004. Check requirements for biodegradability of surfactants, ingredient declaration on packaging (listing ingredient groups in percentage ranges), and the ingredient data sheet that must be made available on a website.

Biodegradability test reports for surfactantsIngredient data sheet for website publication

EU Responsible Person and Economic Operators

Under GPSR (EU) 2023/988, an EU-based responsible person must be designated for each product. This is mandatory for non-EU manufacturers. The responsible person assumes obligations for conformity monitoring, documentation retention, and authority communication.

Estimated time: 1-2 weeks

Designate EU Responsible PersonRequired

Designate an EU-based responsible person according to Art. 16 GPSR. This person must be indicated on the product or packaging with name, postal address, and email address. They are responsible for providing technical documentation, cooperating with market surveillance authorities, and initiating corrective actions for safety issues.

Authorization agreement with the EU Responsible PersonContact details of the responsible person for product labeling

Document obligations as economic operatorRequired

Document your role in the supply chain (manufacturer, importer, distributor, fulfillment service provider). Each role has specific GPSR obligations. Importers must ensure the manufacturer has performed the conformity assessment. Distributors must verify that labeling is complete. Fulfillment service providers (e.g., Amazon FBA) have their own due diligence obligations.

Supply chain organizational chart with roles of all economic operatorsObligation overview per economic operator

Safety Data Sheet and Technical Documentation

Create the Safety Data Sheet (SDS) according to REACH Regulation (EC) 1907/2006 Annex II in German language and the technical documentation according to GPSR. The SDS must contain 16 sections and is mandatory for all cleaning products classified as hazardous.

Estimated time: 2-3 weeks

Create German-language Safety Data Sheet (SDS)Required

Create a complete Safety Data Sheet with all 16 sections according to Regulation (EU) 2020/878 (amendment of REACH Annex II). The SDS must be in German language and contain all hazard statements, first-aid measures, fire-fighting measures, accidental release measures, handling and storage, exposure controls, and personal protective equipment.

Safety Data Sheet (SDS) in German language with 16 sectionsExposure scenarios as annex to SDS (if annual production >10t)

Create technical documentation according to GPSRRequired

Create technical documentation according to Art. 9 GPSR. This must include a general product description, risk analysis, applied standards and specifications, test results, corrective measures, and identification of economic operators. For cleaning products, the internal risk analysis is particularly important as chemical hazards, inhalation risks, and skin contact must be assessed.

Technical documentation with risk analysisTest reports and test results

Poison Centre Notification according to Art. 45 CLPRequired

Notify hazardous mixtures according to Annex VIII of the CLP Regulation via the ECHA Submission Portal (PCN Portal). In Germany, the BfR (Federal Institute for Risk Assessment) is the competent body for poison information. The notification must include a UFI (Unique Formula Identifier) that must also be indicated on the label.

PCN notification confirmation from ECHA portalUFI code generation certificate

Product Labeling and Packaging

Create complete product labeling according to CLP Regulation, Detergents Regulation, and GPSR. German language is mandatory for the German market. Labeling includes GHS hazard pictograms, signal words, H- and P-statements, and product-specific information.

Estimated time: 1-2 weeks

CLP-compliant labeling with GHS pictogramsRequired

Create labels with all CLP mandatory information in German language: product identification, GHS hazard pictograms (red diamond on white background), signal word (Danger/Warning), H-statements, P-statements, nominal quantity, supplier details, UFI code. Observe minimum sizes for pictograms and font according to CLP Annex I, 1.2.1. For the German market, all information must be in German.

Print-ready label designs with CLP conformityLabel approval protocol

Detergent-specific labelingRequired

Add detergent-specific labeling requirements according to Regulation (EC) 648/2004: ingredient list with concentration ranges (<5%, 5-15%, 15-30%, >=30%), dosage instructions (for laundry detergents in grams/milliliters per wash cycle and water hardness level), web address for the full ingredient data sheet, and contact details for the medical professionals data sheet.

Ingredient declaration with percentage rangesDosage instructions (for laundry detergents)

GPSR contact details and traceability on packagingRequired

Ensure the product or packaging bears the following GPSR mandatory information: name and postal address of the manufacturer, name and postal address of the EU Responsible Person (if manufacturer is outside the EU), email address or website for contact, unique product identifier (article number, type, batch or serial number), product designation and product image.

Packaging layout with all GPSR mandatory information

Packaging Registration and Environmental Requirements

Fulfill German packaging and environmental requirements: registration in the LUCID packaging register according to the Packaging Act (VerpackG), system participation with a dual system, and correct disposal instructions on the packaging.

Estimated time: 1-2 weeks

LUCID registration with ZSVRRequired

Register in the LUCID packaging register of the Central Agency Packaging Register (ZSVR) according to the Packaging Act (VerpackG). All first distributors of packaging in Germany must register and report their packaging volumes. Conclude a contract with a dual system (e.g., Der Gruene Punkt, Interseroh, BellandVision) for take-back and recycling.

LUCID registration numberSystem participation contract with dual system

Verify REACH pre-registration and substance registrationRequired

Ensure all chemical ingredients of your cleaning product are registered with ECHA according to REACH Regulation (EC) 1907/2006 (mandatory from 1 tonne/year). Check the SVHC Candidate List (substances of very high concern) and ensure no prohibited substances according to REACH Annex XVII are contained. Also observe the SCIP database notification obligation for articles containing SVHC substances above 0.1%.

REACH registration certificates for all relevant ingredientsSVHC conformity declaration

Amazon.de Hazmat Compliance and Listing Setup

Set up your product listing on Amazon.de and fulfill Amazon's specific Hazmat requirements. Upload all required documents and ensure your product detail page contains all regulatory information.

Estimated time: 1-2 weeks

Amazon Hazmat classification and SDS uploadRequired

Upload the German-language Safety Data Sheet in the Seller Central Hazmat section. Answer Amazon's Hazmat questions correctly (dangerous goods classification, UN number, packing group, limited quantities status). Cleaning products frequently fall under dangerous goods classes 3 (flammable), 8 (corrosive), or 9 (miscellaneous dangerous substances). Note FBA warehouse restrictions for certain hazardous substance classes.

Amazon Hazmat approval confirmationDangerous goods transport classification (UN number, packing group)

GPSR-compliant product detail page and compliance attributesRequired

Fill in all GPSR-relevant attributes in Amazon Seller Central: EU Responsible Person (name, address, email), manufacturer information, warnings, product safety information. Ensure GHS pictograms are visible in product images and all safety instructions are included in German in the product description. Upload conformity documents to the Amazon Compliance Reference section.

Screenshot of the complete Amazon product detail page with all mandatory informationAmazon Compliance Reference uploads (SDS, conformity declarations)

Common Mistakes to Avoid

Safety Data Sheet provided in English only

Consequence: The SDS is rejected by Amazon.de and the listing can be suspended. State authorities can impose fines up to EUR 50,000. End consumers and professional users have no access to critical safety information.

Prevention: Have the Safety Data Sheet translated into German by a qualified chemist or specialized translation service. Ensure all H- and P-statements correspond to the official German versions of the CLP Regulation.

Missing or incorrect GHS pictograms on the label

Consequence: Violation of the CLP Regulation, punishable by fines up to EUR 100,000. Amazon can deactivate the listing. Market surveillance authorities can order a sales stop and recall.

Prevention: Carefully verify the CLP classification and assign the correct GHS pictogram to each H-statement. Use ECHA guidelines for CLP labeling and have labels approved by a hazardous substances expert.

No notification to Poison Centres (missing UFI)

Consequence: Violation of Art. 45 CLP Regulation and Annex VIII. Fines by the competent state authorities. In case of poisoning, physicians lack critical information for treatment, which can lead to liability issues.

Prevention: Notify all hazardous mixtures via the ECHA PCN Portal and generate the UFI code before placing on the market. Print the UFI on the label. Update the notification for every formulation change.

Biocidal product sold without authorization

Consequence: Illegal placing on the market of a non-authorized biocidal product. Criminal offense under the Chemicals Act (ChemG). Fines up to EUR 50,000, in case of deliberate action imprisonment up to 5 years. Amazon account suspension and product recall.

Prevention: Check early whether your product is classified as a biocidal product. Apply for authorization at BAuA in good time, as the process can take several months. Observe transitional provisions for active substances in the review program.

LUCID/VerpackG registration forgotten or quantities incorrectly reported

Consequence: Sales prohibition on Amazon.de. Warning letters from competitors. Fines up to EUR 200,000 by ZSVR. Amazon systematically deactivates listings without valid LUCID number.

Prevention: Register in the LUCID register before the first sale and report your packaging quantities completely and correctly. Ensure your LUCID registration number is deposited in Amazon Seller Central. Perform annual quantity reporting.

Frequently Asked Questions

Q1Do I need a separate Safety Data Sheet for each cleaning product?

Yes, each product with its own formulation requires an individual Safety Data Sheet (SDS) according to REACH Regulation Annex II. If you sell a product under different brand names but the formulation is identical, one SDS referencing the different trade names may be sufficient. The SDS must be in German language and contain all 16 sections.

Q2When is my cleaning product classified as a biocide?

A cleaning product is classified as a biocidal product when it is marketed with the intention to destroy, deter, or render harmless harmful organisms. Typical examples are disinfectants, mold removers with fungicidal action, antibacterial cleaners, and algicides. A regular bathroom cleaner that only removes dirt is not a biocide. The distinction is based on the intended purpose and marketing claims. BAuA provides guidelines for delineation.

Q3What happens if Amazon suspends my listing due to missing Hazmat documents?

In case of a Hazmat suspension, you must upload a correct German-language Safety Data Sheet and, if applicable, an exemption sheet declaration in Seller Central. Amazon reviews documents within 2-5 business days. During suspension, all sales and organic ranking are lost. To avoid this, proactively upload the SDS before the first inventory shipment to Amazon and answer Hazmat questions correctly.

Q4Can SpaceGoats help with GPSR compliance for cleaning products on Amazon.de?

Yes, SpaceGoats comprehensively supports brands with market entry on Amazon.de, including GPSR compliance for cleaning products. The SpaceGoats team assists with Hazmat classification, SDS upload, correct attribute completion for EU Responsible Person and safety information, and listing optimization for regulated products. This allows brands to focus on their core business while Amazon compliance is handled professionally.

Q5Which GHS pictograms are most common for cleaning products?

The most common GHS pictograms for cleaning products are: GHS05 (corrosion) for strongly acidic or alkaline cleaners like drain cleaners and descalers, GHS07 (exclamation mark) for skin-irritating or eye-damaging products like all-purpose cleaners, GHS02 (flame) for alcohol-containing or solvent-containing cleaners, GHS09 (environment) for products harmful to aquatic life. Disinfectants often additionally bear GHS06 (skull and crossbones) for high acute toxicity.

Q6Do I need to fully disclose the ingredients of my cleaning product?

On the label, according to the Detergents Regulation, ingredients must be listed in concentration ranges (<5%, 5-15%, 15-30%, >=30%), not exact percentages. However, a complete ingredient data sheet with INCI names must be made publicly available on a website. Additionally, a data sheet for medical professionals with the complete formulation must be provided upon request. In the Safety Data Sheet, all hazardous ingredients must be listed with CAS numbers and concentrations.

Estimated Costs

300–3,000 EUR

CLP classification and hazard assessment (external chemist)100-500 EUR

Safety Data Sheet creation (German-language, 16 sections)150-600 EUR

Poison Centre notification (PCN/UFI)50-200 EUR

Biocide authorization at BAuA (if applicable)500-2000 EUR

LUCID registration and system participation (dual system)50-300 EUR

Label design and print preparation (CLP/GHS-compliant)100-400 EUR

Timeline

3–10 weeks

Context

Category: Cleaning & Household

Marketplace: amazon.de

Authority: BAuA / BVL / BfArM

MwSt.: 19%

All Checklists Request compliance consulting

Related Glossary Terms

gpsr clp-regulation ghs-pictograms safety-data-sheet eu-responsible-person reach-regulation biocidal-products-regulation detergents-regulation lucid-verpackungsregister verpackg hazmat ufi-code poison-centre-notification baua echa

GPSR (General Product Safety Regulation)Cleaning & HouseholdGermany 🇩🇪

Product Classification and Regulatory Analysis

EU Responsible Person and Economic Operators

Safety Data Sheet and Technical Documentation

Product Labeling and Packaging

Packaging Registration and Environmental Requirements

Amazon.de Hazmat Compliance and Listing Setup

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GPSR (General Product Safety Regulation)
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