Compliance Checklist

GPSR (General Product Safety Regulation)
Food & Beverages
Italy 🇮🇹

Complete checklist for compliance with the EU General Product Safety Regulation (GPSR, EU 2023/988) for food and beverages on the Italian Amazon marketplace, including Italian labeling requirements and food safety regulations.

Overview

The EU General Product Safety Regulation (GPSR, EU 2023/988) has been in effect since December 13, 2024, establishing horizontal safety requirements for consumer products — including food and beverages to the extent they are not fully covered by sector-specific legislation. For food in Italy, the primary frameworks are Regulation (EC) No 178/2002 (General Food Law), the FIC/INCO Regulation (EU 1169/2011), and Italian implementing decree D.Lgs. 231/2017. The GPSR supplements these regulations particularly regarding traceability, responsible economic operator information, and marketplace obligations. Selling on Amazon.it additionally requires compliance with Amazon's grocery category requirements and providing all product information in Italian.

Does this apply to my product?

This checklist applies to all economic operators (manufacturers, importers, distributors, fulfillment service providers) selling food and beverages to Italian consumers on Amazon.it. Covered products include: packaged foods, beverages (including alcoholic beverages), food supplements (where classified as food), specialty and regional products (DOP, IGP, STG). Particularly relevant for non-EU manufacturers and EU importers who must designate a responsible economic operator within the EU.

Step-by-Step Guide

Progress0/16 (0%)

Regulatory Classification and Product Categorization

Determine the regulatory framework for your food product in Italy. Check whether your product falls under the General Food Law, specific regulations (e.g., for food supplements, novel foods, organic products), or additional Italian rules. Clarify your role as an economic operator under the GPSR.

Estimated time: 3-5 days

Identify product category and applicable EU regulationsRequired

Check which EU regulations apply to your food product alongside the GPSR: General Food Law (EC 178/2002), FIC/INCO (EU 1169/2011), possibly Health Claims Regulation (EC 1924/2006), Novel Food Regulation (EU 2015/2283), Organic Regulation (EU 2018/848). For food supplements, Directive 2002/46/EC additionally applies, implemented in Italy by D.Lgs. 169/2004.

Product data sheet with ingredient list and nutritional informationRegulatory mapping matrix (which regulations apply)

Determine your role as economic operator under GPSRRequired

Clarify your role under GPSR: manufacturer (fabbricante), authorized representative (rappresentante autorizzato), importer (importatore), or distributor (distributore). Non-EU manufacturers must designate a responsible economic operator in the EU. As an Amazon.it seller, you are typically an importer or distributor with corresponding due diligence obligations.

Proof of responsible economic operator in the EU (name, address, contact details)

Check Italian special requirements and registration obligationsRequired

Italy has its own additional requirements: D.Lgs. 231/2017 (INCO implementation with Italian penalties), mandatory origin labeling for certain foods (e.g., rice, pasta, tomatoes per various ministerial decrees), registration with ASL (Azienda Sanitaria Locale) for food businesses. Check whether your product intersects with DOP/IGP/STG protections.

Overview of applicable Italian special requirements

Italian Food Labeling and FIC/INCO Compliance

Create or adapt your food labeling to Italian requirements. All mandatory information must appear on the label in Italian language (lingua italiana). Labeling must comply with EU Regulation 1169/2011 (FIC/INCO) and Italian D.Lgs. 231/2017.

Estimated time: 5-10 days

Mandatory label information in Italian languageRequired

The label must contain the following information in Italian per FIC Art. 9 and D.Lgs. 231/2017: name of the food (denominazione dell'alimento), list of ingredients (elenco degli ingredienti), allergens highlighted (allergeni), net quantity (quantita netta), best-before or use-by date (termine minimo di conservazione / data di scadenza), storage conditions (condizioni di conservazione), name/company and address of food business operator (nome/ragione sociale e indirizzo dell'operatore), country of origin/place of provenance (paese d'origine), nutrition declaration (dichiarazione nutrizionale), alcohol content for >1.2% vol.

Final Italian label (print layout or digital mockup)Nutritional analysis from an accredited laboratory or calculated values

Allergen labeling per Italian standardsRequired

All 14 EU major allergens must be highlighted in the ingredient list in Italian (bold, capitals, or other emphasis per FIC Art. 21). Italian terms are: glutine (gluten), crostacei (crustaceans), uova (eggs), pesce (fish), arachidi (peanuts), soia (soy), latte (milk), frutta a guscio (tree nuts), sedano (celery), senape (mustard), sesamo (sesame), anidride solforosa e solfiti (sulphur dioxide/sulphites), lupini (lupin), molluschi (molluscs). The statement 'puo contenere tracce di...' (may contain traces of...) is voluntary but recommended.

Allergen management plan and HACCP documentation

Origin labeling and Italian provenance requirementsRequired

Italy requires mandatory origin labeling for certain food categories beyond EU requirements: pasta (wheat origin), rice (origin), tomato products (tomato origin), milk and dairy products (milk origin). For all products: if omitting origin information could mislead the consumer, it is mandatory (FIC Art. 26). Observe regulations on protected designations of origin (DOP/Denominazione di Origine Protetta, IGP/Indicazione Geografica Protetta).

Origin proof of main ingredients (supplier declarations, certificates)

Food Safety, HACCP, and Traceability

Ensure your food product meets EU food safety regulations and GPSR traceability requirements. In Italy, the Ministry of Health (Ministero della Salute), ASL (Azienda Sanitaria Locale), and NAS oversee food safety. A HACCP plan (Hazard Analysis and Critical Control Points) is mandatory for all food businesses.

Estimated time: 5-10 days

HACCP plan and food safety managementRequired

A HACCP plan is required under EU Regulation (EC) No 852/2004 and Italian implementing legislation for every food business. The plan must identify all critical control points (CCP), establish limits, and document corrective actions. For selling on Amazon.it, you must demonstrate that your supply chain complies with HACCP principles — even if you do not produce yourself.

HACCP plan with hazard analysis and critical control pointsHygiene certificates and staff training records

Traceability per GPSR and food lawRequired

The GPSR (Art. 18) and the General Food Law (Art. 18 of Reg. (EC) 178/2002) require complete traceability. You must document: from whom you sourced the product (one step back) and to whom you supplied it (one step forward). For Amazon.it this means: supplier contracts, batch traceability (tracciabilita del lotto), and the ability to identify and recall all affected batches within a reasonable timeframe.

Traceability system documentation (batches, suppliers, customers)Supplier contracts with traceability clauses

Contaminants, residues, and limit valuesRequired

Ensure your product meets EU and Italian limit values: contaminants per Reg. (EC) 1881/2006 (heavy metals, mycotoxins, dioxins), pesticide residues per Reg. (EC) 396/2005, additives per Reg. (EC) 1333/2008. Italy has stricter implementing provisions in some areas. Laboratory analyses from an accredited lab (laboratorio accreditato ACCREDIA) are recommended.

Laboratory analyses for relevant contaminants and residuesSpecification sheet with limit value compliance

GPSR-Specific Requirements and Documentation

Fulfill the specific GPSR (EU 2023/988) requirements that go beyond sectoral food law: internal risk analysis, technical documentation, consumer contact details, notification obligations via the Safety Gate/RAPEX system, and cooperation with market surveillance authorities.

Estimated time: 3-7 days

Internal risk analysis and technical documentationRequired

The GPSR requires an internal risk analysis for the product (Art. 9). For food, this supplements the existing HACCP analysis with general product safety aspects: packaging safety, choking hazards (especially for products appealing to children), correct usage instructions, and risks from foreseeable misuse. Technical documentation must be retained for at least 10 years.

GPSR risk analysis (supplementary to HACCP hazard analysis)Technical documentation with product specifications and safety assessment

Responsible economic operator and contact informationRequired

Per GPSR Art. 16, the product or packaging must show the name, registered trade name or trademark, and contact address (including postal and electronic address) of a responsible economic operator in the EU. For food, this is typically the food business operator (operatore del settore alimentare, OSA) per FIC. Ensure this information matches between the label and Amazon.it listing.

Designation of responsible economic operator (if different from manufacturer)

Notification obligations and recall planningRequired

The GPSR (Art. 9(7-8)) obliges economic operators to notify competent authorities via the Safety Gate (formerly RAPEX) when they become aware that a product presents a risk. In Italy, the competent authority is the Ministry of Enterprises and Made in Italy in cooperation with the Ministry of Health. Create a recall plan (piano di richiamo) with clear responsibilities, communication channels, and timelines.

Recall plan (piano di richiamo) with escalation proceduresSafety Gate registration and notification procedure documentation

Amazon.it Listing Setup and Grocery Category Requirements

Create your Amazon.it listing considering specific requirements for the 'Alimentari e cura della casa' (Grocery and Household) category. Amazon.it requires additional product information and documentation for food listings and conducts its own quality checks.

Estimated time: 3-5 days

Amazon.it Grocery approval and category requirementsRequired

The food category on Amazon.it is a 'Gated Category' — you need approval (approvazione). Required: business registration, proof of food safety (HACCP), product photos with readable labels, and for certain products analysis certificates. Amazon requires a best-before date of at least 90 days upon delivery to the FBA warehouse and at least 50 days upon delivery to the customer.

Amazon.it Grocery category approval applicationProduct photos with readable Italian labels (all sides of packaging)

Product information and GPSR mandatory details in listingRequired

The Amazon.it listing must contain all relevant product information in Italian: complete ingredient list (elenco ingredienti), allergen information (informazioni sugli allergeni), nutrition declaration (valori nutrizionali), net quantity, storage instructions, serving suggestions, and GPSR mandatory information on the responsible economic operator. Fully utilize Amazon product attributes 'Ingredients', 'Allergen Information', and 'Nutritional Information'.

Amazon.it listing draft with all mandatory fields in Italian

Ongoing Monitoring and Post-Market Compliance

The GPSR and food law require continuous monitoring of product safety after placing on the market. Establish processes for handling customer complaints, monitoring regulatory changes, and cooperating with Italian supervisory authorities.

Estimated time: Ongoing

Complaint management and safety monitoringRequired

Set up a system for recording and analyzing customer complaints and safety notices. The GPSR (Art. 9(6)) requires maintaining a complaint register (registro dei reclami) and investigating safety incidents. Monitor Amazon.it reviews and returns for safety-related complaints. Upon learning of a safety risk, you must immediately notify the competent Italian authority and Amazon.

Complaint register and escalation proceduresPost-market surveillance plan

Regulatory updates and label maintenanceRequired

Italian food law is subject to frequent changes via ministerial decrees (decreti ministeriali) and implementing regulations. Monitor especially: changes to origin labeling obligations, new contaminant limits, updates to the Ministry of Health's food supplement positive list, and changes to Amazon.it category policies. Update labels and listings promptly when regulatory changes occur.

Regulatory monitoring plan with sources and responsibilities

Common Mistakes to Avoid

Label only in English or German — no Italian labeling

Consequence: Sales ban in Italy, fine of EUR 3,000 to 24,000 under D.Lgs. 231/2017, Amazon listing suspension. NAS can seize goods.

Prevention: All mandatory information must appear in Italian on the label. Have the translation reviewed by a native-speaking food law expert — not just a general translator.

Missing or incorrect allergen highlighting in the ingredient list

Consequence: Serious health risk for allergy sufferers, product recall via RASFF, criminal consequences in case of personal injury, fines up to EUR 24,000, Amazon account suspension.

Prevention: Highlight all 14 major allergens in the ingredient list using correct Italian terms (bold or capitals). Embed allergen management system in the HACCP plan and review regularly.

Using protected Italian designations of origin (DOP/IGP) without authorization

Consequence: Criminal proceedings for food fraud (frode alimentare), seizure of goods, fines from EUR 10,000 to 50,000, permanent reputational damage. The NAS and ICQRF (Central Inspectorate for Quality Protection and Fraud Repression) actively pursue such violations.

Prevention: Only use DOP/IGP/STG designations with valid certification. Check the EU eAmbrosia database for all protected designations. Also avoid allusions to protected terms (e.g., 'Parmesan-style' instead of 'Parmigiano').

Missing GPSR mandatory information on responsible economic operator on packaging and listing

Consequence: GPSR violation with fines, Amazon listing suspension due to incomplete GPSR compliance fields, market surveillance proceedings by Italian authorities.

Prevention: Provide name, trademark, and EU contact address (postal and electronic) of the responsible economic operator on the packaging and in the Amazon.it listing. Complete all GPSR fields in Seller Central.

Best-before date too short for Amazon FBA requirements

Consequence: Rejection of goods at FBA warehouse, return at seller's expense, disposal fees, potentially restriction of FBA eligibility for food products.

Prevention: Ensure products have at least 90 days remaining shelf life upon delivery to the FBA warehouse. Plan production and logistics cycles accordingly and account for transit times to Italy.

Frequently Asked Questions

Q1Does my food label for Amazon.it need to be entirely in Italian?

Yes, all mandatory information per FIC/INCO and D.Lgs. 231/2017 must appear in Italian (lingua italiana) on the label. Multilingual labels are permitted as long as the Italian information is complete and clearly legible. Amazon.it verifies this during category approval based on submitted label photos.

Q2How does GPSR compliance for food differ from non-food products?

Food is primarily governed by sectoral food law (EC 178/2002, EU 1169/2011). The GPSR applies supplementarily ('lex generalis'), particularly for: responsible economic operator information, traceability, marketplace obligations, and general product safety (e.g., packaging safety). Unlike non-food, CE marking and EU declaration of conformity are not required — instead, HACCP obligations and food law registrations apply.

Q3Which Italian authorities inspect food on Amazon.it?

Multiple authorities have jurisdiction: the Ministero della Salute (Ministry of Health) for general food safety, the NAS (Nucleo Antisofisticazioni e Sanita dei Carabinieri) for fraud prevention and food crime, the ASL (Azienda Sanitaria Locale) for local hygiene inspections, and the ICQRF (Central Inspectorate for Quality Protection and Fraud Repression) for DOP/IGP protection and quality fraud. The AGCM (Competition and Market Authority) can also intervene for misleading advertising.

Q4Can SpaceGoats support me with GPSR compliance for food on Amazon.it?

Yes, SpaceGoats provides comprehensive support for GPSR compliance for food on Amazon.it: from regulatory classification of your product through coordination of Italian label creation to Amazon category approval and listing setup. SpaceGoats works with specialized Italian food law firms and accredited laboratories to ensure a smooth market entry.

Q5Do I need a separate registration for food supplements in Italy?

Yes, Italy requires a notification (notifica) of food supplements to the Ministry of Health before placing on the market. This is done through the Ministry's online portal. The notification includes submission of the Italian-language label, composition, and scientific evidence. Processing time is typically 60-90 days. Without valid notification, food supplements cannot be sold on Amazon.it.

Q6What are the shelf life requirements for food products with Amazon FBA in Italy?

Amazon requires food products to have at least 90 days remaining shelf life upon delivery to the FBA warehouse and at least 50 days upon delivery to the customer. Products falling below these thresholds are rejected or destroyed. When planning production, account for transit time to Italy (typically 3-7 days within the EU, 2-6 weeks from third countries) and build in a safety buffer.

GPSR (General Product Safety Regulation)Food & BeveragesItaly 🇮🇹