Compliance Checklist

GPSR (General Product Safety Regulation)
Food & Beverages
France 🇫🇷

Complete compliance checklist for the General Product Safety Regulation (GPSR, EU 2023/988) for food and beverages on the French Amazon marketplace. Covers General Food Law, INCO Regulation (EU 1169/2011), French labeling requirements, and DGCCRF enforcement standards.

Overview

The GPSR (EU 2023/988) has been in effect since 13 December 2024, replacing the former General Product Safety Directive. Food and beverages are primarily governed by the General Food Law (Regulation EC 178/2002) and the INCO Regulation (EU 1169/2011) for labeling. The GPSR applies supplementarily to food-adjacent products (packaging, accessories, novel food products) and establishes overarching safety and traceability obligations. In France, the DGCCRF (Direction Generale de la Concurrence, de la Consommation et de la Repression des Fraudes), DGAL (Direction Generale de l'Alimentation), and ANSES (Agence nationale de securite sanitaire) oversee enforcement. Amazon.fr increasingly requires GPSR-compliant product listings with economic operator information, French-language labeling, and full traceability.

Does this apply to my product?

This checklist applies to all food and beverages sold on Amazon.fr, including packaged foods, supplement-adjacent products, beverages, snacks, and specialty items. The GPSR specifically covers food-adjacent products such as novel packaging concepts, kitchen appliances with food contact, and food gift sets. Pure food products are primarily governed by the General Food Law and INCO, but GPSR requirements for economic operators and traceability must also be met. Non-EU manufacturers need an EU-based responsible economic operator (Responsible Person). France has specific requirements for French-language labeling, allergen declarations, origin labeling, and the Loi AGEC (Triman logo, sorting instructions).

Step-by-Step Guide

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Product Classification and Regulatory Mapping

Determine whether your product falls primarily under the General Food Law / INCO or whether GPSR requirements apply directly (e.g., for food-contact materials, packaging, kitchen appliances). Review French-specific regulations.

Estimated time: 3-5 days

Verify regulatory classificationRequired

Verify whether your product is classified as a food (General Food Law, EC 178/2002), food-contact material (Regulation EC 1935/2004), novel food (EU 2015/2283), or food-adjacent consumer product under GPSR. Consider French special categories such as AOC/AOP and IGP-protected products.

Product data sheet with classificationMapping to applicable EU regulations

Define economic operator roleRequired

Define your role under GPSR: manufacturer, importer, distributor, or fulfilment service provider. Non-EU manufacturers must designate an EU-based authorised representative (Mandataire / Responsible Person) who must be listed on the product and in the Amazon listing.

Power of attorney for the authorised representative (Mandataire)GPSR economic operator registration

Review French market access requirementsRequired

Review specific French requirements: Code de la Consommation (Consumer Code), Loi AGEC (Anti-Waste for a Circular Economy Act), DGCCRF registration obligations, and special food regulations from DGAL. Certain product categories (alcohol, organic food, novel food) require additional approvals.

French special requirements checklist

French-Language Labeling and INCO Compliance

Prepare complete French-language labels in accordance with INCO (EU 1169/2011) and French law. All mandatory information must be provided in French — this is legally required in France (Loi Toubon).

Estimated time: 5-10 days

INCO-compliant mandatory labeling in FrenchRequired

Create French-language labels with all INCO mandatory information: food name (denomination de vente), ingredients list (liste des ingredients), allergens highlighted (allergenes en gras), net quantity (quantite nette), best-before date (date de durabilite minimale / DDM) or use-by date (date limite de consommation / DLC), storage conditions (conditions de conservation), food business operator name and address, country of origin (pays d'origine), nutrition declaration (declaration nutritionnelle), and lot number (numero de lot).

French-language label (draft and final version)INCO compliance verification

Allergen declaration per French standardsRequired

The 14 INCO main allergens must be clearly highlighted in the ingredients list using a different typeset (in France typically bold or uppercase). Use French terms: gluten, crustaces, oeufs, poissons, arachides, soja, lait, fruits a coque, celeri, moutarde, sesame, sulfites, lupin, mollusques. Extended information obligations apply for non-prepacked foods (vente en vrac).

Allergen management documentationIngredients list with highlighted allergens

Origin labeling and French special rulesRequired

France has strict origin labeling requirements that exceed EU minimum standards. Mandatory origin indication for meat (Decret n° 2022-65), milk and dairy products, honey, fruits and vegetables. For processed products, the primary ingredient origin must be stated when product origin is suggested. AOC, AOP, IGP, and Label Rouge products are subject to additional labeling rules.

Origin certificates and supply chain documentation

Loi AGEC, Nutri-Score, and Environmental Labeling

Meet French environmental and sustainability labeling obligations under Loi AGEC (Loi Anti-Gaspillage pour une Economie Circulaire). Review applicability of Nutri-Score and Eco-Score.

Estimated time: 3-7 days

Triman logo and sorting instructions (Info-Tri)Required

Since 1 January 2022, all consumer products with packaging sold in France must display the Triman logo together with the Info-Tri (sorting instructions). For food packaging, the Info-Tri must indicate which packaging components go into which bin (Bac de tri / Poubelle). The marking must be on the packaging itself or an enclosed document. For online sales, the information must also be provided digitally.

Packaging design with Triman logo and Info-TriCITEO registration certificate (packaging license)

Evaluate Nutri-Score and Eco-Score

The Nutri-Score (nutrition traffic light, A to E) is voluntary in France but expected by a large majority of French consumers and preferred by Amazon.fr buyers. When used, it must be correctly calculated (algorithm by Sante Publique France). The Eco-Score (environmental rating, A to E) is also voluntary but gaining importance. Both scores can be used in Amazon listings as additional trust signals.

Nutri-Score calculation and registration with Sante Publique FranceEco-Score calculation (if applicable)

EPR registration for packaging (CITEO)Required

Under Loi AGEC and French Extended Producer Responsibility (Responsabilite Elargie du Producteur / REP), all companies placing packaged food on the French market must be registered with an approved eco-organization (eco-organisme). For packaging, CITEO is the primary contact. The UPN (Unique Producer Number / Numero Unique de Producteur) must be registered with Amazon.fr.

CITEO contract and UPN numberAnnual packaging declaration (Declaration annuelle)

GPSR Safety Assessment and Documentation

Prepare GPSR-compliant safety documentation for your food product, including risk analysis, technical documentation, and traceability system.

Estimated time: 5-10 days

Prepare risk analysis and safety assessmentRequired

Prepare a risk analysis per GPSR Art. 6-8 considering food-specific risks: microbiological contamination, chemical residues, physical hazards, allergens, packaging migration. Consider French ANSES recommendations and DGCCRF guidelines. The assessment must include foreseeable consumer misuse (e.g., storage at incorrect temperature, use after expiry date).

GPSR risk analysis (food safety)HACCP plan or equivalent safety concept

Technical documentation and traceabilityRequired

Prepare technical documentation per GPSR Art. 9, which must be retained for at least 10 years. For food products, this includes: product specifications, ingredient origin, certificates of analysis (COA), laboratory reports, HACCP documentation, and a complete traceability system (Tracabilite) per Art. 18 of Regulation EC 178/2002 (one step back, one step forward).

Technical product documentation (GPSR Art. 9)Traceability protocol with supplier and batch dataCertificates of analysis (COA) for each batch

Recall plan and corrective market actionsRequired

Prepare a recall plan (Plan de retrait/rappel) per GPSR Art. 14 and DGCCRF requirements. The plan must include procedures for product recall via Amazon.fr (FBA and FBM), notification to DGCCRF via the RappelConso portal, and customer information. For serious risks, notification to the Safety Gate database (formerly RAPEX) and the French RappelConso system is mandatory.

Recall plan with Amazon.fr-specific proceduresRappelConso access registration

Amazon.fr Listing Compliance and GPSR Mandatory Information

Set up your Amazon.fr listing in GPSR compliance, including all mandatory information on economic operators, safety information, and French-language product description.

Estimated time: 3-5 days

Enter GPSR mandatory information in Amazon listingRequired

Enter the following GPSR mandatory information in your Amazon.fr listing: manufacturer name and address, EU Responsible Person name and address (Mandataire), consumer contact details (including email address), product identification (EAN/GTIN, batch number, model number). All information must be available in French. Use the Amazon GPSR fields in Seller Central.

Amazon.fr listing with GPSR fields completedScreenshot of GPSR compliance information

French-language product description and safety noticesRequired

Create a complete French-language product description for Amazon.fr containing all relevant safety notices: consumption recommendations (Conseils de consommation), warnings (Avertissements), storage instructions (Conditions de conservation), allergen warnings (Avertissement allergenes), and target-group-specific warnings (e.g., not suitable for children under 3, not for pregnant women). Product images must show the French label clearly legible.

French-language Amazon product descriptionProduct images with legible French label

Monitoring, Post-Market Obligations, and Ongoing Compliance

Establish systems for ongoing GPSR compliance, post-market surveillance, and French reporting obligations.

Estimated time: 2-5 days

Establish post-market surveillance systemRequired

Set up a post-market surveillance system (systeme de surveillance apres-mise sur le marche) per GPSR Art. 14. For food products, this includes: monitoring Amazon.fr customer reviews for safety signals, regular batch testing, monitoring RASFF notifications and the RappelConso database, analysis of customer complaints regarding quality and safety, and regular review of expiry dates in FBA warehouses.

Post-market surveillance planComplaint log and analysis

Regular compliance review and updatesRequired

Schedule regular compliance reviews: quarterly label review for regulatory changes, annual renewal of CITEO declaration (Declaration annuelle), monitoring of DGCCRF publications and ANSES opinions, risk analysis update when formulations change or new scientific evidence emerges, and review of Amazon GPSR fields for currency.

Compliance calendar with deadlinesCompliance review records

Common Mistakes to Avoid

Missing French-language labeling (violation of Loi Toubon)

Consequence: DGCCRF can impose fines up to EUR 7,500 per violation, Amazon.fr can immediately suspend listings. Repeated violations can lead to complete account suspension.

Prevention: Have all labels and Amazon listings reviewed by a French native speaker with labeling expertise. Use the correct French technical terms (DDM, DLC, denomination de vente).

Missing or incorrect allergen highlighting in the ingredients list

Consequence: Serious health risk for allergic consumers, product recall via RappelConso, DGCCRF fine, potential liability for health damages, and massive reputation damage on Amazon.fr.

Prevention: Conduct a complete allergen analysis (including cross-contamination risks), have labels reviewed by a food law expert, and test the highlighting (bold/uppercase) on the final printed label.

Missing CITEO registration and Triman logo

Consequence: Fines up to EUR 100,000 for missing EPR registration under Loi AGEC, Amazon.fr listing suspension due to missing UPN number, and back-payment of EPR contributions for all units sold since market entry.

Prevention: Register with CITEO before your first sale on Amazon.fr, integrate the Triman logo and Info-Tri into your packaging design, and register the UPN number in Amazon Seller Central immediately.

Missing GPSR Responsible Person in Amazon listing

Consequence: Amazon.fr suspends listings without registered GPSR economic operator data. For non-EU sellers without a Mandataire in the EU, selling on Amazon.fr is effectively impossible.

Prevention: Designate an EU Authorised Representative (Mandataire) before creating the listing, complete all GPSR mandatory fields in Amazon Seller Central, and regularly verify that the information is still current.

False or exaggerated origin claims (e.g., 'Made in France' for imported raw materials)

Consequence: Fines up to EUR 300,000 for misleading origin claims per Code de la Consommation (Art. L121-2), DGCCRF proceedings for consumer deception (Pratique commerciale trompeuse), and Amazon A-to-Z guarantee claims from misled buyers.

Prevention: Use only verifiable origin claims, document the entire supply chain, and review French rules for made-in claims (Decret sur l'origine) before using them.

Frequently Asked Questions

Q1Does the GPSR apply directly to food or only to food-adjacent products?

Food products are primarily governed by the General Food Law (EC 178/2002) and INCO Regulation (EU 1169/2011) for safety and labeling. The GPSR applies supplementarily for overarching aspects such as the obligation to designate an economic operator, traceability requirements, and post-market surveillance. For food-adjacent products (packaging, kitchen utensils with food contact, food gift sets), the GPSR applies directly. Amazon.fr requires GPSR mandatory information for all product categories, including food.

Q2Is the Nutri-Score mandatory for food products on Amazon.fr?

The Nutri-Score is currently voluntary in France (as of June 2026) but is actively promoted by the French government and expected by the majority of French consumers. Over 1,000 brands in France already use the Nutri-Score. If you choose to use it, it must be correctly calculated per the Sante Publique France algorithm and registered with the competent authority. Displaying an incorrect Nutri-Score constitutes a violation of French consumer law.

Q3How do I find an approved EU Authorised Representative (Mandataire) for food products in France?

For GPSR compliance, the Mandataire must be based in the EU, not necessarily in France. However, they must be able to communicate in French and cooperate with French authorities (DGCCRF, DGAL). SpaceGoats supports Amazon sellers in identifying suitable Mandataire service providers and correctly setting up GPSR mandatory information in Amazon Seller Central — contact the SpaceGoats team for individual consultation.

Q4What penalties apply for non-compliance with Loi AGEC for food packaging?

Loi AGEC provides significant penalties: up to EUR 100,000 fine for missing EPR registration (CITEO), up to EUR 15,000 for missing Triman logo or sorting instructions (Info-Tri), and Amazon.fr can suspend listings without a valid UPN number. Additionally, retroactive EPR contributions may be levied for all units sold since market entry. The DGCCRF is increasingly conducting online checks on marketplaces.

Q5Do dietary supplements on Amazon.fr need to meet additional requirements?

Yes, dietary supplements (Complements alimentaires) are subject to additional strict regulations in France. They must be notified to the DGCCRF via the Teleicare portal (Declaration under Article 15 of Decree 2006-352). Permitted ingredients and maximum levels are set in French Arretes and may differ from EU minimum standards. Health claims must be approved per the EU Health Claims Regulation (EC 1924/2006) and formulated in French. The DGCCRF conducts regular market surveillance for dietary supplements on online marketplaces.

Q6Can I sell food products with a German label on Amazon.fr?

No. Per the Loi Toubon and INCO Regulation, all mandatory food information in France must be in French. A purely German-language label is not permissible. You need either a completely French label or a multilingual label containing all INCO mandatory information in French. For Amazon FBA shipments to France, the French label must be applied before shipping to the FBA warehouse. Retroactive sticker labels are permissible but must contain all mandatory information and adhere permanently.

GPSR (General Product Safety Regulation)Food & BeveragesFrance 🇫🇷