Compliance Checklist

GPSR (General Product Safety Regulation)
Pet Supplies
Germany 🇩🇪

EU General Product Safety Regulation (GPSR) for pet supplies on Amazon Germany: safety requirements, electronic pet devices, EU Responsible Person and common mistakes.

Overview

Pet supplies have been subject to the EU General Product Safety Regulation (GPSR, Regulation 2023/988) since 13 December 2024. Although there is no specific EU harmonisation directive for most pet products, they must fully comply with the GPSR as safe consumer products. This covers toys for animals, leashes and collars, transport crates, grooming accessories, food and water bowls, and electronic pet devices (GPS trackers, automatic feeders, electric grooming devices). Electronic pet devices must additionally comply with CE directives. Market surveillance in Germany is carried out by state authorities and the Federal Institute for Occupational Safety and Health (BAuA).

Does this apply to my product?

This checklist applies to all pet supplies sold on Amazon.de: dog leashes, collars, harnesses, pet toys, scratching and climbing trees, aquarium accessories, transport crates, food and water bowls, grooming accessories (brushes, scissors, nail clippers), pet beds, electronic devices (GPS trackers, automatic feeders, camera collars, anti-bark devices, heated beds, automatic litter boxes). Excluded are pet food and veterinary medicines, which fall under separate regulations.

Step-by-Step Guide

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Analyse product risks and determine GPSR requirements

The GPSR requires a risk analysis for every product. For pet products, risks to both animals and humans (especially children) must be considered.

Estimated time: 2-5 days

Risk analysis conducted (animal and human safety)Required

Analyse risks for animals (choking hazard, strangulation from leashes, toxic materials, sharp edges) and for humans (especially children who might play with pet toys, injury risk from accessories). Electronic devices: additionally overheating, electric shock, battery risks.

Additional CE requirements for electronic pet devices identifiedRequired

Electronic pet devices (GPS trackers, automatic feeders, heated beds, ultrasonic devices) must additionally comply with CE directives beyond the GPSR: LVD (if applicable), EMC Directive, RED (for radio devices like GPS trackers). The GPSR closes gaps not covered by CE.

Conduct safety testing and material tests

Have your pet products tested for relevant safety aspects. While there is no single EN standard for all pet products, numerous applicable standards exist.

Estimated time: 2-6 weeks

Material safety testing conductedRequired

Test materials for harmful substances: REACH conformity (especially SVHC substances), AZO dyes for textile products (leashes, harnesses, beds), phthalates and BPA for plastic products (bowls, toys), heavy metals for coated products. Products with skin contact for the animal are subject to similar standards as consumer products.

Material test reports / REACH conformity declaration

Mechanical safety testing conductedRequired

Test mechanical safety aspects: tear resistance of leashes and collars, load capacity of clasps and carabiners, edge sharpness, small parts risk (especially if children may have access), stability of climbing structures and transport crates.

CE testing for electronic devices conducted (if applicable)

Electronic pet devices must meet relevant CE standards: EN 62368-1 (safety), EN 55032/55035 (EMC), EN 301 489 and EN 300 328 (for Bluetooth/WiFi devices). Have testing carried out by an accredited laboratory.

CE test reports for electronic components

EU Responsible Person and product labelling

The GPSR requires the appointment of an EU-based economic operator and correct product labelling with German safety information.

Estimated time: 1-2 weeks

EU Responsible Person / authorised representative appointedRequired

Non-EU manufacturers must appoint an EU-based economic operator. Name, postal address and electronic contact details must be stated on the product, packaging or accompanying document.

Authorisation agreement with EU Responsible Person

Product labelling in German preparedRequired

All safety-relevant information, instructions for use and warnings must be in German. Mandatory information: manufacturer/importer with address, EU Responsible Person, batch or serial number, warnings (e.g. 'Not suitable for children under 3 years' for small parts), instructions for use.

Amazon.de listing requirements and GPSR documentation

Meet the GPSR-related requirements for your Amazon.de listing and keep all compliance documents ready.

Estimated time: 2-5 days

GPSR mandatory information entered in Amazon Seller CentralRequired

Enter the manufacturer/importer and EU Responsible Person with name, postal address and email/URL in Seller Central. Amazon has been checking this information since December 2024 and may suspend listings without complete information.

Compliance documentation complete and readily availableRequired

Keep the following documents ready: risk analysis, material test reports, CE documentation (for electronic devices), REACH conformity declaration, instructions for use in German, photos of labelling. Market surveillance or Amazon may request these at any time.

Risk analysis, test reports, REACH declaration, instructions for use

Common Mistakes to Avoid

Pet products considered unregulated because there is no specific EU directive

Consequence: The GPSR serves as a catch-all regulation for all consumer products without specific harmonisation legislation. Pet products are subject to the full GPSR including risk analysis, Responsible Person, traceability and reporting obligations. Non-compliance can lead to fines and sales bans.

Prevention: Treat pet products with the same diligence as regulated consumer products. Conduct a complete GPSR conformity assessment.

Risk to children not considered for pet toys

Consequence: Children frequently interact with pet toys. Swallowable small parts, toxic materials or sharp edges can be dangerous for children. Market surveillance assesses foreseeable use – not just intended use.

Prevention: Explicitly consider children's interaction with the pet product in your risk analysis. Apply warnings if necessary such as 'Not a children's toy' or 'Not suitable for children under 3 years'.

Electronic pet devices assessed only under GPSR without CE conformity

Consequence: Electronic pet devices require both CE marking (LVD, EMC, RED if applicable) and GPSR conformity. Without CE marking, placing on the EU market is illegal and can lead to seizure and fines.

Prevention: Conduct a combined CE and GPSR assessment for electronic pet devices. Ensure all relevant CE directives are met and the GPSR closes remaining gaps.

No instructions for use in German included

Consequence: German consumers are entitled to safety information in German. Missing German instructions can increase liability in case of accidents and be objected to by market surveillance.

Prevention: Include German-language instructions for use with every product. For simple products, a leaflet suffices; for electronic devices, complete instructions are required.

Frequently Asked Questions

Q1Are pet products really subject to the GPSR?

Yes. The GPSR applies to all consumer products placed on the EU market unless they are fully covered by a specific EU harmonisation regulation. Since there is no specific directive for most pet products, they fall fully under the GPSR.

Q2Do I really need a risk analysis for a simple dog collar?

Yes, the GPSR requires an appropriate risk analysis for every product. For a simple dog collar, however, this can be pragmatic: material safety (no toxic substances, no sharp edges), tear resistance, clasp safety and possible strangulation risk for small dogs. Document the analysis in writing.

Q3My GPS tracker for dogs already has CE – is that enough for the GPSR?

CE covers the technical aspects (radio, EMC, safety). The GPSR additionally requires: EU Responsible Person on the product, traceability, German instructions for use, online selling obligations and Safety Gate reporting duties. You must comply with both.

Q4Can pet toys fall under the Toy Safety Directive?

Generally not, as the Toy Safety Directive only applies to products designed or intended for children under 14 to play with. However, if your pet toy is designed in a way that it could easily be confused with a children's toy (e.g. a plush toy sold as a dog toy), market surveillance may classify it as a children's toy. Label pet toys clearly.

Q5Which testing standards apply to dog leashes and collars?

There is no uniform EN standard for dog leashes and collars. In practice, tensile strength tests, wear tests and material tests (REACH conformity, AZO dyes) are commonly carried out. Some manufacturers refer to DIN 75410 (restraint systems for dogs in vehicles) as a reference for load tests.

GPSR (General Product Safety Regulation)Pet SuppliesGermany 🇩🇪

Analyse product risks and determine GPSR requirements

Conduct safety testing and material tests

EU Responsible Person and product labelling

Amazon.de listing requirements and GPSR documentation

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