Compliance Checklist

GPSR (General Product Safety Regulation)
Food & Beverages
Germany 🇩🇪

Complete GPSR checklist for food and beverages on Amazon Germany. Step-by-step guide with costs, timeline, common mistakes and the interplay of GPSR, LMIV and the General Food Law.

Overview

The General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) has applied since December 13, 2024 to all consumer products in the EU. Food itself is primarily regulated by the General Food Law (Regulation (EC) 178/2002) and the Food Information Regulation (FIR/LMIV, Regulation (EU) 1169/2011). However, the GPSR applies supplementarily to food-adjacent products: food contact materials (cutting boards, storage containers), kitchen tools sold together with food, and general product safety aspects that go beyond sector-specific food regulation (e.g. packaging safety, choking hazards from small parts on food packaging). For Amazon.de sellers in the Food & Beverages category this means: in addition to complying with LMIV (allergen labeling, nutrition table, best-before/use-by dates) and the General Food Law, the GPSR mandatory fields in Seller Central must be completed and traceability and market surveillance requirements must be met. In Germany, the Federal Office of Consumer Protection and Food Safety (BVL) and the state consumer protection agencies (Landesaemter) oversee enforcement.

Does this apply to my product?

This checklist applies to all economic operators selling food and beverages on Amazon.de. This includes: packaged foods (snacks, canned goods, dried products, beverages), food supplements (supplements), specialty foods (organic, gluten-free, vegan), food sets containing kitchen accessories (e.g. gift baskets with cutting boards), and food contact materials bundled with food products. LMIV requirements (allergen labeling of the 14 main allergens, nutrition declaration, best-before date (MHD) or use-by date (Verbrauchsdatum), origin labeling) apply independently of the GPSR. The GPSR supplements these with general safety, labeling and traceability obligations – particularly relevant for Amazon Seller Central compliance fields.

Step-by-Step Guide

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Clarify regulatory classification and economic operator role

Determine which regulations apply to your food products and what role you hold as an economic operator under the GPSR. Food falls primarily under the General Food Law (EC 178/2002) and LMIV (EU 1169/2011). The GPSR supplements these for general product safety and Amazon compliance fields.

Estimated time: 1-2 Tage

Economic operator role (food business operator) documentedRequired

Document in writing whether you are a manufacturer, importer or distributor. Under the General Food Law you are registered as a food business operator (FBO). Under the GPSR: private label sellers are classified as manufacturers; those importing food from outside the EU are importers. Your role determines your labeling and traceability obligations.

Registration proof as food business operator with the responsible state authority

Responsible person in the EU designated (if based outside the EU)Required

If your company is based outside the EU, you must designate a responsible person (Authorized Representative) in the EU under the GPSR. Additionally, food law requires an EU-based importer who is liable as a food business operator. Both roles can be held by the same entity.

Power of attorney / appointment letter for the EU Authorized Representative

Applicable regulations per product type identifiedRequired

Create a matrix of your products with applicable regulations: LMIV (all food), Health Claims Regulation (EC 1924/2006) for nutrition/health claims, Novel Food Regulation (EU 2015/2283) for novel ingredients, GPSR for general product safety and Amazon mandatory fields, and where applicable EU Regulation 2015/2283 for food supplements.

Ensure food safety and risk assessment

The GPSR requires a risk assessment for all consumer products. For food, this is covered by the HACCP concept (Hazard Analysis and Critical Control Points) and the due diligence obligations of the General Food Law. The GPSR supplements this with packaging safety aspects, choking hazards and product presentation risks.

Estimated time: 3-7 Tage

HACCP concept documented and implementedRequired

Every food business operator must maintain a HACCP concept per Regulation (EC) 852/2004. Document all critical control points (CCPs), limits, monitoring measures and corrective actions. This covers the majority of the GPSR risk assessment for food products.

HACCP documentation with hazard analysis, CCPs and corrective actions

Supplementary GPSR risk assessment for packaging and presentationRequired

Assess risks beyond food safety itself: choking hazards from packaging parts (e.g. film packaging for children's products), injury risks from packaging design (sharp edges on cans), food contact material compliance (Regulation (EC) 1935/2004) for packaging in contact with food.

GPSR risk assessment for packaging and product presentation risks

Declaration of conformity for food contact materials availableRequired

All materials in direct food contact (packaging, included accessories) must comply with Regulation (EC) 1935/2004. Request a Declaration of Compliance (DoC) from your suppliers confirming the migration limits (OML/SML) are met.

Declaration of Compliance (DoC) for food contact materials per (EC) 1935/2004

Ensure LMIV-compliant labeling

The Food Information Regulation (LMIV, EU 1169/2011) mandates comprehensive labeling requirements that must be fulfilled in German for sales on Amazon.de. These obligations exist independently of the GPSR but are equally critical for Amazon Grocery compliance.

Estimated time: 3-5 Tage

Complete LMIV mandatory labeling on packaging (in German)Required

Ensure all LMIV mandatory information is on the packaging: food name, ingredients list, allergen labeling (14 main allergens highlighted, e.g. bold), net quantity, best-before date (MHD) or use-by date, name and address of food business operator, country/place of origin (where prescribed), nutrition declaration (Big 7), alcohol content (for beverages >1.2% vol.), storage instructions and directions for use (where necessary). All in German.

Label approval with verified LMIV conformity

Nutrition declaration (Big 7) correctly statedRequired

The nutrition declaration must contain the Big 7: energy (kJ and kcal), fat, of which saturates, carbohydrates, of which sugars, protein and salt – per 100g or 100ml. Additional per-portion information is voluntary. Table format is mandatory; exceptions apply only for very small packaging.

Lot number / batch number on packagingRequired

Per the Lot Marking Directive (2011/91/EU) and GPSR traceability requirements, each food product must carry a lot number (letter 'L' followed by the number) or batch number. For products with a best-before date, this can serve as the lot number if it includes day and month.

GPSR mandatory fields and Amazon Seller Central compliance

Amazon introduced new GPSR mandatory fields in Seller Central since December 2024. For food products, these must be completed in addition to existing Grocery requirements (product images with label, ingredients list in the listing).

Estimated time: 1-3 Tage

GPSR mandatory fields completed in Amazon Seller CentralRequired

For each ASIN the following fields must be maintained in Seller Central: Responsible Person (name, address, email), Manufacturer (name, address, email), warnings and safety information. Use the bulk upload function for many ASINs. Amazon actively checks these fields and can deactivate listings with missing information.

Economic operator contact details on physical packagingRequired

The GPSR requires on the product or packaging: name, trade name or brand, postal address and email address of the manufacturer (or EU responsible person for non-EU companies). A website URL alone is NOT sufficient. For food, the LMIV mandatory food business operator declaration partially covers this – but verify that an email address is also provided.

Amazon Grocery-specific listing requirements metRequired

Beyond GPSR fields, Amazon requires for the Food & Beverages category: product images with visible label (front and back), ingredients list in listing text, allergen warnings, nutrition information, net quantity, best-before date information (Amazon requires a remaining shelf life of at least 90 days for FBA delivery).

Build traceability and documentation systems

The General Food Law (Art. 18 of Regulation (EC) 178/2002) and the GPSR require seamless traceability. For food, the 'one step back, one step forward' principle applies – you must be able to document your suppliers and your customers.

Estimated time: 2-4 Tage

Traceability system per Art. 18 EC 178/2002 implementedRequired

Document for each batch: supplier (name, address, delivery date), recipient/buyer, batch/lot numbers, quantities and delivery dates. For Amazon FBA: link batch numbers with FBA Shipment IDs. The system must enable tracing within 24 hours.

Traceability documentation with supplier and batch mapping

Rapid alert system and recall process establishedRequired

Familiarize yourself with RASFF (Rapid Alert System for Food and Feed) and the Safety Gate system. In Germany, the BVL is the RASFF contact point. For serious food safety risks, you must inform the responsible state authority within 24 hours. Define an internal recall process that also covers Amazon FBA inventory.

Internal recall plan with responsibilities and reporting channels (BVL, state authorities, Amazon)

Ongoing market surveillance and compliance maintenance

Both the GPSR and food law require continuous market surveillance. You must systematically capture customer complaints, evaluate product changes and track regulatory updates.

Estimated time: Laufend / 1-2 Stunden pro Woche

Complaint management process for food safety establishedRequired

Set up a systematic process: monitor Amazon reviews and buyer messages for safety reports (e.g. foreign bodies, allergic reactions, spoiled goods), document and evaluate each complaint, escalation process for safety risks with reporting to BVL/state authorities.

Regular labeling review when formulations changeRequired

With every change to the recipe, ingredients list or manufacturing process, labeling (physical label and Amazon listing), nutrition declaration and allergen warnings must be updated. Document changes with version number and date.

Common Mistakes to Avoid

GPSR mandatory fields in Seller Central not filled because 'food is already regulated'

Consequence: Amazon deactivates listings without GPSR mandatory fields regardless of product category. Revenue loss and loss of best seller ranking position during suspension.

Prevention: The GPSR applies IN ADDITION to food-specific regulations. Complete all Seller Central mandatory fields (Responsible Person, Manufacturer, contact details) for each ASIN.

Allergen labeling not highlighted in LMIV-compliant manner

Consequence: Violation of Art. 21 LMIV – fines up to 50,000 EUR in Germany. Health risk for allergy sufferers and possible product recall via RASFF. Amazon can block the ASIN in the Grocery category.

Prevention: Visually highlight all 14 main allergens in the ingredients list (bold, UPPERCASE or underlined). Also state 'May contain traces of...' for cross-contamination risks.

Best-before date (MHD) missing or incorrectly formatted

Consequence: Amazon FBA rejects delivery or destroys goods with unclear best-before dates. Violation of LMIV Art. 24 with fine risk. Particularly critical: confusion of best-before date and use-by date for highly perishable products.

Prevention: State best-before date in format 'Mindestens haltbar bis DD.MM.YYYY'. For highly perishable foods (e.g. fresh meat, fresh cheese) use 'Zu verbrauchen bis DD.MM.YYYY' instead. Amazon FBA requires at least 90 days remaining shelf life.

No EU responsible person designated and no EU importer registration for third-country goods

Consequence: Product may not be placed on the EU market – violation of both GPSR AND General Food Law simultaneously. Amazon increasingly blocks listings without a designated EU responsible person. Customs authorities can refuse import.

Prevention: Appoint an EU Authorized Representative and a registered EU importer. SPACEGOATS offers this service as EC-REP specifically for Amazon sellers, covering both functions.

Nutrition declaration missing or only available in English

Consequence: Violation of LMIV Art. 9 and Art. 15 (language requirement). All mandatory information must be in German on the packaging. Amazon can deactivate the listing and food safety authorities can impose fines.

Prevention: Ensure the complete nutrition declaration (Big 7) is in German and in the prescribed table format on the packaging. For multi-packs: each individual package must be fully labeled.

Frequently Asked Questions

Q1Does the GPSR even apply to food if the LMIV and General Food Law already exist?

Yes, but supplementarily. Food falls primarily under sector-specific regulation (LMIV, Regulation (EC) 178/2002). The GPSR fills gaps for general product safety aspects: packaging safety, product presentation risks, included accessories and – particularly relevant in practice – the Amazon GPSR mandatory fields in Seller Central. Every Amazon food seller must complete these fields, regardless of whether the product is already regulated by sector-specific legislation.

Q2What happens if my Amazon food listing doesn't have the GPSR fields?

Amazon deactivates the listing or blocks the ASIN entirely. Since December 2024, Amazon actively checks the 'Responsible Person' and 'Manufacturer Information' fields – including for food. A listing suspension leads to immediate revenue loss and can permanently damage your organic ranking, as Amazon downgrades blocked ASINs in its ranking algorithm.

Q3As a non-EU food seller, do I need both an importer and a GPSR authorized representative?

Yes, in principle you need both: an EU-based importer registered as a food business operator (mandatory under the General Food Law), and a GPSR Authorized Representative. Both roles can be fulfilled by the same organization. SPACEGOATS offers as an EC-REP service provider for Amazon sellers a solution that covers both requirements.

Q4What special requirements apply to food supplements on Amazon.de?

Food supplements are additionally subject to the German Food Supplement Regulation (NemV) beyond LMIV and GPSR. They must be notified to the BVL (notification obligation per §5 NemV). Special labeling requirements include: designation 'food supplement', nutrient amounts per daily portion, recommended daily dose, warning 'Do not exceed the recommended daily dose', note that supplements are not a substitute for a balanced diet, and 'Keep out of reach of children'. Health claims must comply with the Health Claims Regulation (EC 1924/2006).

Q5How do I handle multilingual labels for multiple EU markets?

Multilingual labels are permitted and common for Pan-EU strategies on Amazon. The LMIV requires mandatory information in a language easily understood by the consumer – for Amazon.de mandatorily in German. Practical recommendation: create a master label with DE/EN/FR/IT/ES and check minimum font size (1.2mm x-height, for small packages under 80cm² surface: 0.9mm). LMIV mandatory information must be complete in each national language – no mixing of languages within a mandatory field.

Q6What costs can I expect to bring a single food product to Amazon.de in GPSR and LMIV compliance?

For a single food product, expect 200-2,000 EUR: label review and adaptation (150-500 EUR), nutritional analysis in laboratory (80-250 EUR if needed), HACCP documentation (200-800 EUR if not yet available), packaging adaptation (100-400 EUR). Add annual costs for EC-REP (200-1,200 EUR/year) if you don't have an EU presence. For multiple products, unit costs decrease considerably as HACCP and many processes are reusable.

GPSR (General Product Safety Regulation)Food & BeveragesGermany 🇩🇪