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Compliance Checklist

GPSR (General Product Safety Regulation)
Pet Supplies
France ๐Ÿ‡ซ๐Ÿ‡ท

Complete checklist for compliance with the EU General Product Safety Regulation (GPSR, EU 2023/988) for pet products on the French Amazon marketplace โ€” including food, toys, beds, bowls, and accessories.

Overview

The EU General Product Safety Regulation (GPSR, EU 2023/988) has applied since 13 December 2024 to all consumer products on the EU market โ€” including pet supplies. For the French market (Amazon.fr), sellers must ensure that pet products such as toys, beds, bowls, and accessories meet general safety requirements. Pet food is additionally governed by Regulation (EC) No 767/2009 on the placing on the market and use of feed, with GPSR supplementing requirements for non-food pet items. France has particularly active enforcement authorities in the DGCCRF (Direction Generale de la Concurrence, de la Consommation et de la Repression des Fraudes) and the DGAL (Direction Generale de l'Alimentation) for feed safety. French-language labeling is legally mandated (Code de la consommation, Art. L.112-1). An EU-based Responsible Person is mandatory for every non-EU manufacturer.

Does this apply to my product?

This checklist applies to all pet products sold on Amazon.fr: pet toys, beds and sleeping accessories, food bowls and water dispensers, leashes, collars and harnesses, grooming products, carriers, and accessories. For pet food and treats, additional requirements under Regulation (EC) 767/2009 and French feed legislation apply (supervised by DGAL and ANSES). GPSR obligations apply equally to manufacturers, importers, distributors, and fulfilment service providers. Special attention is required for products that come into contact with food-contact materials (bowls) or that pose potential choking hazards (toys with small parts).

Step-by-Step Guide

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1

Product Classification and Regulatory Mapping

Determine which regulations apply to your pet product: GPSR alone (non-food products) or GPSR plus Regulation 767/2009 (feed products). Identify product-specific standards and French supplementary requirements.

Estimated time: 3-5 days

2

Establish EU Responsible Person and Traceability

Designate an EU-based Responsible Person per GPSR Art. 16 and establish a complete traceability system.

Estimated time: 1-2 weeks

3

French-Language Labeling and Packaging

Create fully French-language product labels that comply with both GPSR and French national requirements (Loi AGEC, Code de la consommation).

Estimated time: 1-2 weeks

4

Technical Documentation and Conformity Evidence

Create and maintain technical documentation per GPSR Art. 9 and product-specific conformity evidence.

Estimated time: 2-3 weeks

5

Amazon.fr Listing Compliance and Seller Central Setup

Ensure your Amazon.fr product listings contain all GPSR mandatory information and meet Amazon-specific compliance requirements.

Estimated time: 3-5 days

6

Market Surveillance, Reporting Obligations, and Ongoing Compliance

Establish processes for ongoing market surveillance, reporting obligations for safety issues, and continuous GPSR compliance.

Estimated time: ongoing (initial setup 3-5 days)

Common Mistakes to Avoid

Missing or incomplete French translation of safety notices

Consequence: The DGCCRF can impose an immediate sales ban and fines up to EUR 15,000 per violation for natural persons (EUR 75,000 for legal entities) per Code de la consommation Art. L.132-1. Amazon.fr may suppress the listing without prior notice.

Prevention: Commission professional translators with regulatory experience and have all texts proofread by a French native speaker before print approval.

No EU Responsible Person designated or not registered in Amazon Seller Central

Consequence: Listing suppression by Amazon since December 2024, no possibility to resume sales until correct registration. Additionally, regulatory measures by the DGCCRF may follow during inspections.

Prevention: Designate the EU Responsible Person before first placing on the market and enter the data in all Amazon listings immediately. Regularly verify that the data remains current.

Missing Triman logo and Info-tri on packaging

Consequence: Violation of Loi AGEC with fines up to EUR 15,000 for natural persons and EUR 75,000 for legal entities. CITEO (French EPR system for packaging) may additionally levy penalty fees.

Prevention: Integrate the Triman logo and component-specific Info-tri into packaging design from the outset. Use the CITEO guide for correct design of sorting instructions.

Selling food bowls without Food Contact Materials compliance

Consequence: Food bowls that come into contact with pet food may fall under EU Regulation 1935/2004. Missing migration tests can lead to product recalls and significant liability claims, particularly if harmful substances migrate.

Prevention: Have all food bowls and water dispensers tested for migration per EU 10/2011 (plastics) or relevant individual measures (ceramics, metals). Retain the Declaration of Compliance.

Selling pet food without DGAL-compliant labeling per Regulation 767/2009

Consequence: The DGAL (Direction Generale de l'Alimentation) can stop sales, seize batches, and impose fines. For health-endangering deficiencies, criminal consequences may follow. Amazon.fr may suspend the entire seller account for repeated violations.

Prevention: Ensure all feed labels fully meet the requirements of Regulation 767/2009: composition in descending order, analytical constituents, feed type designation, batch number, best-before date โ€” all in French.

Frequently Asked Questions

Q1Does GPSR apply to pet food or only to non-food products?

Pet food is primarily governed by Regulation (EC) 767/2009 on the placing on the market and use of feed, which contains specific safety, labeling, and traceability requirements. GPSR supplements these requirements for aspects not covered by the feed regulation (e.g. packaging safety). For non-food pet products (toys, beds, bowls, accessories), GPSR is the primary legal basis. In practice, sellers must observe both regulatory frameworks when offering a mixed pet product range on Amazon.fr.

Q2Do pet products need to bear a CE marking in France?

No, pet products generally do not require a CE marking. CE marking applies to products falling under specific EU harmonisation legislation (e.g. Toy Safety Directive for children's toys, Low Voltage Directive for electrical devices). Pet toys are not equivalent to children's toys and do not fall under Toy Safety Directive 2009/48/EC. However, electrical pet products (e.g. automatic feeders, heated beds) may fall under the Low Voltage Directive or other harmonisation legislation and then require CE marking.

Q3What happens if Amazon.fr suppresses my pet product listing due to missing GPSR data?

If Amazon.fr suppresses a listing due to missing GPSR mandatory information, you must add the missing data (manufacturer details, EU Responsible Person, product identification) in Seller Central and then request reinstatement. Processing time is typically 24-72 hours. For repeated violations or missing data across many ASINs, Amazon may temporarily restrict the entire seller account. SpaceGoats can assist with correct data entry and the reinstatement process to minimise revenue loss.

Q4How does compliance for pet food differ from pet accessories?

Compliance requirements differ significantly: Pet food falls under Regulation 767/2009 (Feed Regulation) and is supervised by DGAL and ANSES โ€” with strict requirements for composition statements, analytical constituents, feeding guidelines, and best-before dates. Manufacturers and importers must be registered as feed business operators. Pet accessories (toys, beds, leashes) fall directly under GPSR and are supervised by the DGCCRF โ€” here mechanical and chemical safety, labeling, and traceability are the focus. Both categories require French-language labeling and Triman/Info-tri on packaging.

Q5Do I need separate technical documentation for each individual pet product?

Not necessarily for each individual product, but for each product family or product type with different safety characteristics. Products from the same production line, using the same materials and with identical safety properties can be grouped in one Technical File (e.g. a range of dog collars of the same design in different sizes). Once materials, construction, or risk profile change, a separate Technical File is required. SpaceGoats recommends defining a clear product family structure to keep documentation efforts efficient.

Q6What role does ANSES play in pet product compliance in France?

ANSES (Agence nationale de securite sanitaire de l'alimentation, de l'environnement et du travail) is France's national health safety agency. For pet products, ANSES assesses risks to animal health, publishes scientific opinions on feed safety and chemical substances in pet products, and advises the DGAL and DGCCRF on regulatory decisions. ANSES also operates the French nutrivigilance system for feed, through which adverse effects of pet food are reported. Sellers should follow ANSES publications for their product category, as these frequently form the basis for intensified inspections by the DGCCRF.