Compliance Checklist

GPSR (General Product Safety Regulation)
Clothing & Fashion
Germany 🇩🇪

Complete GPSR compliance checklist for clothing on Amazon.de. Economic operator obligations, risk assessment, labeling and traceability under EU Regulation 2023/988 (General Product Safety Regulation).

Overview

The EU General Product Safety Regulation (GPSR, (EU) 2023/988) has been in force since December 13, 2024, replacing the old Product Safety Directive 2001/95/EC. The GPSR applies to ALL consumer products - including clothing and textiles. For Amazon clothing sellers, this means: determining the economic operator role, conducting product risk assessment, placing contact details on the product or packaging, designating a responsible person in the EU (if based outside the EU), and ensuring traceability. Amazon has integrated GPSR requirements into its compliance programs and can suspend listings without correct GPSR information.

Does this apply to my product?

This checklist applies to all sellers of clothing and textiles on Amazon.de: outerwear (jackets, trousers, shirts, dresses), underwear and nightwear, sportswear, children's clothing, scarves, hats, gloves, socks, hosiery, swimwear, and textile accessories (belts, fabric bags). Special attention is required for children's clothing (choking hazard from cords/drawstrings), nightwear (flammability), and clothing with decorative elements (small parts, sequins, buttons).

Step-by-Step Guide

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Determine Economic Operator Role under GPSR

The GPSR defines different obligations for manufacturers, importers, distributors, and fulfillment service providers. Your role determines the scope of your obligations.

Estimated time: 1 Tag

Determine economic operator role: manufacturer, importer or distributorRequired

You are a manufacturer if you place clothing on the EU market under your own name/brand (including private label). You are an importer if you bring clothing from outside the EU (e.g., from Turkey, Bangladesh, China, India). You are a distributor if you resell clothing already in the EU. Manufacturers and importers have the most comprehensive obligations.

Conduct Risk Assessment for Clothing Products

Manufacturers and importers must conduct a risk assessment considering all possible product hazards. For clothing, specific risks must be evaluated.

Estimated time: 2-5 Tage

Identify and document product-specific risksRequired

Assess the following risks for your clothing products: mechanical risks (cords and drawstrings on children's clothing per EN 14682, loose small parts like buttons, sequins, rhinestones on children's clothing, sharp edges on zippers or metal decoration), chemical risks (azo dyes, formaldehyde, nickel in metal parts, pH value), flammability (especially nightwear and costumes), and choking risks (polybag packaging for children's clothing). Document the risk assessment in writing.

Written risk analysis/risk assessment

Consider safety standards for clothingRequired

Relevant harmonized standards: EN 14682 (cords and drawstrings on children's clothing), EN ISO 3758 (care labeling), EN 14878 (flammability of children's nightwear), Oeko-Tex Standard 100 (pollutant testing, voluntary but recommended by Amazon). Compliance with harmonized standards triggers a presumption of conformity - the product is considered safe.

Apply Labeling and Contact Details on Product/Packaging

The GPSR significantly tightens labeling requirements compared to the old directive. Contact details must be visible on the product or packaging.

Estimated time: 1-3 Tage

Ensure mandatory information on label and packagingRequired

The following information must appear on the clothing label or packaging: name/company name and postal address of the manufacturer (or importer if manufacturer is outside the EU), contact details of a responsible person in the EU (if manufacturer outside EU), product identification (e.g., model number, EAN/GTIN, batch number or other identification), care labeling per EN ISO 3758, textile labeling (fiber composition per EU Textile Labeling Regulation (EU) No 1007/2011), and size indication.

Designate responsible person in the EU (if required)Required

If the manufacturer is not based in the EU, a responsible person must be designated in the EU. This person serves as contact for authorities and Amazon, must be able to provide technical documentation and risk assessment, and is responsible for communication in case of safety issues. SpaceGoats can act as responsible person in the EU.

Written appointment of the responsible person

Ensure Traceability and Amazon GPSR Compliance

The GPSR strengthens traceability requirements. Every product must be uniquely identifiable and the supply chain must be documented.

Estimated time: 1-2 Tage

Ensure traceability throughout the supply chainRequired

Every clothing item must be uniquely identifiable through a product/model number, EAN/GTIN, batch number, or other identification feature. Document your supply chain: name and address of manufacturer, importer, and all intermediaries. Keep this information for at least 10 years. In case of a recall, you must be able to quickly identify affected batches.

Maintain Amazon GPSR product attributes in Seller CentralRequired

Since 2025, Amazon requires GPSR-relevant information in product details: manufacturer name and address, responsible person name and address in the EU (if applicable), warnings and safety information (if applicable). These can be entered in the listing editor under compliance fields. Missing GPSR attributes can lead to listing suspension.

Common Mistakes to Avoid

GPSR considered not relevant for clothing because there is no specific EU clothing directive

Consequence: The GPSR applies to ALL consumer products, even if not regulated by sector-specific EU legislation. Clothing without GPSR-compliant labeling can be suspended by Amazon and challenged by authorities.

Prevention: Treat every clothing product as GPSR-obligated. Ensure contact details, product identification, and traceability are present on all labels and packaging.

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

Consequence: Cords on children's clothing are one of the most common causes of RAPEX notifications (EU rapid alert system). Non-compliant products are immediately removed from the market. Amazon suspends listings and the ASIN can be permanently blocked.

Prevention: Check every children's clothing item (0-14 years) for cords, drawstrings, loops, and decorative ribbons per EN 14682. Cords at the hood and neck area are completely prohibited on toddler clothing.

Frequently Asked Questions

Q1Does the GPSR also apply to clothing sold only via Amazon FBA?

Yes. The GPSR applies regardless of sales channel to all consumer products placed on the EU market. Amazon FBA sellers are affected equally as traditional retailers. Additionally, the GPSR imposes extended obligations on online marketplaces.

Q2Do I need a responsible person in the EU if my company is based in the EU?

No. The obligation to designate a responsible person only applies if the manufacturer is based outside the EU and no importer or authorized representative exists in the EU. If your company is registered in Germany or another EU country, you are the responsible economic operator yourself.

Q3What happens if I don't fill in the GPSR attributes in my Amazon listing?

Amazon can suspend listings without complete GPSR attributes. Since 2025, Amazon actively checks GPSR mandatory fields (manufacturer details, responsible person). Suspension can affect all ASINs under the affected brand. SpaceGoats handles GPSR compliance for your clothing products completely.

GPSR (General Product Safety Regulation)Clothing & FashionGermany 🇩🇪

Determine Economic Operator Role under GPSR

Conduct Risk Assessment for Clothing Products

Apply Labeling and Contact Details on Product/Packaging

Ensure Traceability and Amazon GPSR Compliance

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