Compliance Checklist

GPSR (General Product Safety Regulation)
Clothing & Fashion
France 🇫🇷

Complete GPSR compliance checklist for clothing and fashion products on Amazon.fr. Product safety requirements, EU responsible person, and traceability under Regulation (EU) 2023/988.

Overview

The General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) has been in effect since December 13, 2024, replacing the old Product Safety Directive. For clothing and fashion sellers on Amazon.fr, this means stricter obligations: every textile product must ensure clear traceability, carry contact details of a responsible economic operator in the EU, and have undergone a risk assessment. The French market surveillance authority DGCCRF (Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes) enforces the GPSR in France and regularly conducts inspections of online marketplaces.

Does this apply to my product?

This checklist applies to all manufacturers, importers, and distributors selling clothing and fashion products on the French market via Amazon.fr. This includes outerwear, underwear, sportswear, accessories (scarves, gloves, belts), footwear, bags, and children's clothing. Products with drawstrings, small parts, or chemically treated textiles require special attention.

Step-by-Step Guide

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Determine Economic Operator Role and Responsible Person

The GPSR defines clear obligations per role: manufacturer, authorised representative, importer, or distributor. For non-EU companies, a responsible person in the EU is mandatory.

Estimated time: 1-3 Tage

Identify your role as economic operatorRequired

Determine your role under GPSR: manufacturer (you design/produce under your own name), importer (you bring non-EU goods into the EU), or distributor (you resell goods from an EU manufacturer). Private label sellers qualify as manufacturers. Each role has different obligations regarding documentation and risk assessment.

Designate responsible person in the EU (if based outside EU)Required

Under the GPSR, every product on the EU market must have a responsible person based in the EU. This person must be indicated on the product or packaging with name, postal address, and email address. They serve as contact for market surveillance authorities and must be able to provide technical documentation upon request.

Mandate agreement with the responsible person in the EU

Conduct Risk Assessment and Safety Evaluation

The GPSR requires an internal risk analysis for every product. For clothing, mechanical risks (choking hazard from small parts, strangulation from cords) and chemical risks (REACH restrictions for textile chemicals) must be assessed in particular.

Estimated time: 3-7 Tage

Create internal risk analysis for textile productsRequired

Conduct a risk analysis covering: mechanical safety (cords, buttons, zippers, rivets), chemical safety (dyes, plasticizers, flame retardants per REACH Annex XVII), flammability, and age-appropriate design for children's clothing (EN 14682 for cords and drawstrings).

Documented risk analysis (internal document)

Identify and comply with relevant standardsRequired

Even though clothing has no CE requirement, European standards serve as proof of product safety: EN ISO 12947 (abrasion resistance), EN 14682 (safety of cords and drawstrings in children's clothing), EN ISO 3758 (care labeling), EN 14878 (burning behavior of children's nightwear). Compliance with these standards creates a presumption of conformity.

Ensure Labeling and Traceability

The GPSR tightens labeling requirements: every product must be uniquely identifiable and allow tracing back to the manufacturer/importer. For the French market, the Textile Labeling Regulation (EU) 1007/2011 and French language requirements additionally apply.

Estimated time: 2-5 Tage

Apply mandatory information on product and packagingRequired

The following must appear on the product or packaging: name/company name and postal address of the manufacturer (or EU responsible person), email address, product designation or unique identifier (e.g., GTIN/EAN, model number), batch or serial number for traceability, warnings in French language.

Labeling template with all mandatory information

Textile labeling per EU Regulation 1007/2011Required

Fiber composition must be indicated as percentage by weight in descending order (e.g., '80% cotton, 20% polyester'). Fiber designations must be in French ('coton', 'polyester', 'laine' etc.). Multi-component textiles (lining, interlinings) require separate declarations per component.

Establish traceability systemRequired

Implement a traceability system across the entire supply chain: batch/lot numbers for each production batch, documentation of suppliers and subcontractors, ability to disclose the entire supply chain within 10 days (DGCCRF requirement during market surveillance inspections).

Create and Maintain Technical Documentation

Manufacturers and importers must maintain technical documentation that can be presented to DGCCRF within 10 days upon request. The documentation must enable proof of product safety.

Estimated time: 3-7 Tage

Compile technical documentationRequired

Technical documentation must include: general product description with images, risk analysis and evaluation of measures, applied standards (e.g., EN 14682), test reports (if conducted), supplier registry and proof of origin, label and packaging samples, declaration of conformity.

Technical documentation (retention obligation: 10 years after placing on market)

Obtain test reports for critical product properties

For risk-bearing textile products, accredited lab tests should be available: azo dyes (EN 14362), formaldehyde (EN ISO 14184), pH value (EN ISO 3071), nickel release from metal parts (EN 1811), phthalates in printed textiles. DGCCRF frequently requests test results during inspections.

Meet Amazon.fr GPSR Requirements

Amazon actively enforces the GPSR on its marketplace and requires sellers to provide specific data in Seller Central. Non-compliance risks listing suspension.

Estimated time: 1-2 Tage

Enter GPSR mandatory data in Amazon Seller CentralRequired

Enter for each ASIN in Seller Central: manufacturer name and address, EU Responsible Person name and address, email for safety notifications, warnings and safety information in French. Amazon provides specific input fields for this since December 2024.

Upload product images showing visible label/tag

Upload product images for your clothing ASINs showing the care label with fiber composition, manufacturer details, and any warnings. This increases trust and can serve as evidence during Amazon's GPSR compliance checks.

Common Mistakes to Avoid

No EU responsible person indicated on the label

Consequence: Amazon suspends listings without EU Responsible Person. DGCCRF can impose fines up to EUR 15,000 (natural person) or EUR 75,000 (legal entity) and prohibit distribution.

Prevention: Ensure name, postal address, and email of a responsible person based in the EU appears on every label or packaging — before shipping goods to France.

Cords and drawstrings in children's clothing not checked per EN 14682

Consequence: Strangulation risk for children. RAPEX notification (EU Safety Gate), immediate recall, reputational damage, and potential criminal consequences in France.

Prevention: Check every children's garment for cords, drawstrings, and functional cords per EN 14682. For children under 7, cords in the head/neck area are completely prohibited.

Missing French language version on labels

Consequence: Violation of Loi Toubon. DGCCRF can flag products and have them removed from the market. Amazon France increasingly rejects listings with non-French warnings.

Prevention: All consumer-relevant information (fiber composition, care instructions, warnings, manufacturer details) must be in French on the label. Multilingual labels are permissible.

No risk analysis conducted for clothing products

Consequence: During DGCCRF inspections, missing risk analysis can trigger immediate measures: sales ban, forced recall, and fines. The burden of proof lies with the economic operator.

Prevention: Document a risk analysis for each product group — for clothing at minimum: mechanical risks, chemical risks (dyes, coatings), flammability, and allergens.

Frequently Asked Questions

Q1Does clothing need CE marking for the French market?

No. Clothing and textiles do not require CE marking as they do not fall under a CE-mandatory EU directive. However, GPSR requirements (product safety, traceability, responsible person) and the Textile Labeling Regulation (EU) 1007/2011 apply. Exception: Personal Protective Equipment (PPE) such as safety shoes or protective clothing requires CE.

Q2What are the specific DGCCRF requirements for textile products?

DGCCRF inspects textiles primarily for: correct fiber composition (max 3% deviation from declared value), French language on all labels, REACH-compliant chemicals (especially azo dyes, formaldehyde, nickel), children's clothing safety (EN 14682), and since 2024 the GPSR mandatory data (responsible person, traceability).

Q3Do I as an Amazon seller need my own EU Responsible Person?

If your company is based outside the EU: Yes. The GPSR requires that a responsible natural or legal person based in the EU must be designated for every product on the EU market. Amazon has actively enforced this since December 2024. If you have an EU business address, you fulfill this role yourself.

Q4What penalties apply for GPSR violations in France?

In France, DGCCRF can take the following measures: fines up to EUR 15,000 (natural person) or EUR 75,000 (legal entity) per violation, product recall and market withdrawal, publication of violations (name-and-shame), and for serious safety defects criminal prosecution with prison sentences up to 2 years.

Q5How long must I keep the technical documentation?

Technical documentation must be kept for 10 years after the last placing on the market. It must be presentable to DGCCRF within 10 working days upon request in French or English. Digital storage is permissible.

GPSR (General Product Safety Regulation)Clothing & FashionFrance 🇫🇷