Compliance Checklist

GPSR (General Product Safety Regulation)
Pet Supplies
Spain 🇪🇸

Complete checklist for compliance with the EU General Product Safety Regulation (GPSR, EU 2023/988) for pet supplies on the Spanish Amazon marketplace. Covers requirements from the Ministerio de Consumo, AESAN regulations for pet food, and regional enforcement by the Comunidades Autonomas.

Overview

The EU General Product Safety Regulation (GPSR, Regulation EU 2023/988) has been in effect since December 13, 2024, replacing the previous General Product Safety Directive. For pet supplies on Amazon.es, this means comprehensive requirements for product safety, traceability, and documentation. In Spain, the Ministerio de Consumo (Ministry of Consumer Affairs) is the central authority for product safety, while AESAN (Agencia Espanola de Seguridad Alimentaria y Nutricion) is specifically responsible for pet food. The Comunidades Autonomas (Autonomous Communities) handle regional market surveillance. All product information, warnings, and labeling must be provided in Spanish (castellano). The Spanish pet market is growing steadily — over 29 million pets live in Spanish households — making Amazon.es an attractive but regulatory demanding sales channel.

Does this apply to my product?

This checklist applies to all economic operators (manufacturers, importers, distributors, fulfillment service providers) selling pet supplies via Amazon.es in Spain. This includes: pet food and treats (additionally regulated under Regulation 767/2009), toys and accessories for pets, grooming products (shampoos, brushes, etc.), carriers and leashes, beds, bowls and automatic feeders, aquarium and terrarium accessories, and pet clothing. Excluded are prescription veterinary medicines (under Directive 2001/82/EC) and certain biocidal products (under EU Biocidal Products Regulation 528/2012). For pet food, the additional requirements of Regulation (EC) No. 767/2009 on the placing on the market and use of feed apply.

Step-by-Step Guide

Progress0/14 (0%)

Designate EU Responsible Person (Responsable en la UE)

According to GPSR Article 16, an EU-based responsible person must be designated for each product to serve as the point of contact for authorities and consumers. For the Spanish market, this person must be reachable in Spanish.

Estimated time: 1-2 weeks

Designate EU Responsible Person based in the EURequired

A natural or legal person established in the EU must be designated as the responsible person (persona responsable). This person assumes the tasks under GPSR Art. 16(3), including providing safety information and cooperating with market surveillance authorities such as the Ministerio de Consumo and the Comunidades Autonomas.

Authorization agreement (contrato de representacion) with the EU Responsible PersonProof of EU establishment (trade register extract / extracto del registro mercantil)

Display contact details on the product and on Amazon.esRequired

The name, postal address, and email address of the EU Responsible Person must be displayed on the product or its packaging. Additionally, Amazon.es requires this data to be entered in Seller Central under the mandatory GPSR attributes (atributos obligatorios de GPSR).

Updated product labels with contact details in Spanish

Document the tasks and obligations of the responsible personRequired

The division of tasks between manufacturer/importer and EU Responsible Person must be contractually defined. This includes: handling complaints, cooperating with the Ministerio de Consumo and Safety Gate/RAPEX, forwarding safety-relevant information, and access to technical documentation.

Service agreement with task description

Conduct Product Safety and Conformity Assessment

Under the GPSR, all pet supply products must undergo an internal risk analysis. For pet food, the additional requirements of Regulation (EC) No. 767/2009 and national AESAN guidelines apply.

Estimated time: 2-4 weeks

Conduct internal risk analysis (analisis de riesgos)Required

According to GPSR Art. 9, an internal risk analysis must be conducted to identify all foreseeable risks of the product. For pet supplies, particular attention must be given to: choking hazards (small parts in toys), chemical safety (harmful substances in materials), mechanical safety (sharp edges, breakage risk), electrical safety (for heated products or automatic feeders), and suffocation risk from packaging materials.

Risk analysis report (informe de analisis de riesgos) per product categoryTest reports from accredited laboratories (informes de ensayo) where applicable

Verify specific requirements for pet food (Reg. 767/2009 / AESAN)Required

Pet food is additionally subject to Regulation (EC) No. 767/2009 on the placing on the market and use of feed. In Spain, AESAN (Agencia Espanola de Seguridad Alimentaria y Nutricion) monitors compliance. Mandatory information includes: composition, analytical constituents, feed additives, feeding instructions, best-before date (fecha de durabilidad minima), batch number (numero de lote), and manufacturer details — all in Spanish language.

Feed labeling (etiquetado de piensos) according to Reg. 767/2009 in SpanishRegistration as feed business operator (operador de empresa de piensos) with AESAN or the competent autonomous authority

Prepare technical documentation (documentacion tecnica)Required

According to GPSR Art. 9(2), technical documentation must be prepared and retained for at least 10 years after placing on the market. This includes: general product description, risk analysis results, applied standards and specifications, test reports, images and drawings, and a list of applied harmonized standards or other solutions.

Complete technical documentation per product/product family

Ensure Product Labeling and Traceability

The GPSR sets strict requirements for product labeling and traceability. All information must be provided in Spanish (castellano) for the Spanish market.

Estimated time: 1-2 weeks

Apply mandatory labeling in SpanishRequired

The following information must be indicated on the product, packaging, or accompanying document in Spanish: product name and type, name and address of the manufacturer and importer if applicable, name and address of the EU Responsible Person, warnings (advertencias) and safety information, batch number (numero de lote) or serial number, country of origin. Under Spanish consumer protection law (Real Decreto Legislativo 1/2007), all consumer-relevant information must be available in Castellano.

Spanish product labels (etiquetas de producto) for all variantsSpanish safety instructions and user manuals (instrucciones de uso)

Establish traceability system (sistema de trazabilidad)Required

According to GPSR Art. 18, economic operators must establish a traceability system that allows the entire supply chain to be traced. Each product must be traceable via batch number, serial number, or other identification. Manufacturers and importers must maintain records of suppliers and buyers — this is particularly relevant for Amazon FBA logistics (Logistica de Amazon), where goods movements must be documented traceably.

Documented traceability system with batch/serial number mappingSupplier and buyer lists (listas de proveedores y distribuidores)

Configure Amazon.es Seller Central GPSR Attributes

Amazon.es has required specific mandatory GPSR attributes for all listings since December 2024. Missing information leads to listing suppression.

Estimated time: 3-5 days

Enter mandatory GPSR attributes in Seller CentralRequired

The following GPSR attributes must be completed in Amazon Seller Central: manufacturer name and address (fabricante), EU Responsible Person name and address (responsable en la UE), product safety warnings in Spanish (advertencias de seguridad del producto), product safety images/warning pictograms. This information can be entered individually or uploaded via flat file (archivo plano) for larger catalogs.

Completed GPSR mandatory fields in Seller Central for each ASINSafety data sheets or warning images (imagenes de advertencia)

Review product images and A+ Content for GPSR complianceRequired

Product images must clearly show Spanish labels, warnings, and GPSR mandatory information. A+ Content (contenido A+) should also include safety information and usage instructions in Spanish. Amazon may flag listings without visible Spanish labeling.

Updated product images with visible Spanish labeling

Establish Notification and Recall Procedures

The GPSR requires functional processes for accident reporting, product recalls, and communication with authorities. For Spain, the Ministerio de Consumo and Safety Gate (RAPEX) are the central points of contact.

Estimated time: 1-2 weeks

Define accident notification process (procedimiento de notificacion de accidentes)Required

According to GPSR Art. 20, economic operators must notify Safety Gate (formerly RAPEX) about dangerous products. In Spain, notification is made through the Ministerio de Consumo, which operates the national RAPEX contact point. The notification process must be documented and include internal escalation paths for Amazon customer feedback (comentarios de clientes).

Documented notification process (protocolo de notificacion) for Safety Gate/RAPEXInternal escalation plan for safety-related Amazon customer complaints

Create recall plan (plan de retirada)Required

A recall plan must be in place defining the steps in case of a product recall: notification of authorities (Ministerio de Consumo), consumer information in Spanish, coordination with Amazon.es for FBA inventory (inventario FBA), retrieval and disposal/correction of affected products. The plan must consider the specific Amazon FBA logistics, as Amazon has its own removal order processes.

Written recall plan with Amazon FBA-specific processesTemplate consumer notification (notificacion al consumidor) in Spanish

Fulfill Packaging EPR and Additional Spanish Obligations

In addition to the GPSR, Spain has additional obligations through Extended Producer Responsibility (EPR) for packaging under Ley 7/2022 de Residuos y Suelos Contaminados. These are closely linked to the GPSR compliance process.

Estimated time: 1-2 weeks

Under Ley 7/2022 de Residuos y Suelos Contaminados (Waste and Contaminated Soil Act), those placing packaging on the Spanish market must join an authorized take-back system. Ecoembes is the dominant packaging EPR system in Spain. Registration is mandatory for all sellers bringing products in packaging to Spain — including primary, secondary, and transport packaging.

Ecoembes registration confirmation (certificado de adhesion)Annual packaging volume declaration (declaracion anual de envases)

Ensure packaging labeling according to Spanish regulationsRequired

Spain requires correct packaging labeling with material identification and disposal instructions under Real Decreto 1055/2022. The Triman symbol is relevant for France but not for Spain — instead, the Punto Verde (Green Dot) should be used with Ecoembes membership (optional since 2023, but recommended). Packaging materials must be marked with standardized material abbreviations (e.g., PAP 21 for cardboard, LDPE 4 for plastic).

Packaging designs with correct material labeling

Common Mistakes to Avoid

Missing or incomplete Spanish translation of product labeling

Consequence: Suppression of Amazon.es listing and potential fines from the Ministerio de Consumo. Under Real Decreto Legislativo 1/2007, consumer protection violations can be penalized with fines from EUR 3,005 to EUR 601,012 depending on severity.

Prevention: All consumer-relevant information, warnings, and instructions must be professionally translated into Spanish (castellano). Use native-speaking translators and have the texts reviewed by a compliance expert.

No EU Responsible Person designated or not entered in Seller Central

Consequence: Amazon.es has been automatically suppressing listings without mandatory GPSR attributes since December 2024. Additionally, regulatory measures from the Ministerio de Consumo may follow, including sales bans and recall orders.

Prevention: Designate the EU Responsible Person early and correctly enter all contact details both on the product and in the Amazon Seller Central GPSR fields.

Selling pet food without registration as a feed business operator

Consequence: Violations of Regulation (EC) 767/2009 and Spanish feed law can lead to seizure of goods, sales bans, and fines from AESAN or the competent Comunidad Autonoma.

Prevention: Before the first sale of pet food on Amazon.es, check whether registration in the RGSEAA is required. When in doubt, consult AESAN or the competent regional authority.

Missing Ecoembes registration for packaging EPR

Consequence: Violations of Ley 7/2022 can lead to fines from EUR 1,001 to EUR 3,500,000 (depending on classification as minor, serious, or very serious violation). The Comunidades Autonomas are responsible for enforcement.

Prevention: Complete Ecoembes registration before market entry and submit the annual packaging volume declaration on time. Registration is possible online via ecoembes.com.

Using FNSKU as the sole traceability identifier

Consequence: The FNSKU is an Amazon-internal identifier and does not meet GPSR traceability requirements. During an inspection by the Ministerio de Consumo or the Comunidades Autonomas, the absence of a batch number on the product can be considered a violation.

Prevention: Each product must be physically marked with a batch number (numero de lote) or serial number that enables traceability throughout the entire supply chain — independent of the Amazon FNSKU.

Frequently Asked Questions

Q1Does the GPSR also apply to handmade or self-mixed pet treats?

Yes. The GPSR applies to all consumer products made available on the EU market — regardless of whether they are industrially or handcrafted. Handmade pet treats are additionally subject to Regulation (EC) 767/2009 if they qualify as feed. In Spain, the manufacturer must also be registered with the RGSEAA.

Q2Must warnings on pet toys be in Spanish even if the product has uniform EU-wide packaging?

Yes. Spain requires under Real Decreto Legislativo 1/2007 that all consumer-relevant information be provided in castellano (Spanish). Uniform EU packaging without Spanish is not compliant for the Spanish market. Adhesive labels (pegatinas) or inserts with Spanish information are acceptable.

Q3Is CE marking required for cat litter or dog beds?

No. CE marking only applies to products that fall under specific EU harmonization legislation (e.g., Toy Directive, Machinery Regulation). Most pet supply items such as cat litter, beds, or simple accessories do not fall under these. However, they are subject to the GPSR as the catch-all regulation for general product safety. Exception: Electrical products such as heated pet beds or automatic feeders may fall under the Low Voltage Directive and would then require CE marking.

Q4What happens if Amazon.es suppresses my listing due to missing GPSR attributes?

Since December 2024, Amazon.es suppresses listings where the mandatory GPSR fields are not filled in. To lift the suppression, you must add the manufacturer details, EU Responsible Person information, and safety warnings (in Spanish) in Seller Central. After completion, Amazon typically reviews the information within 24-48 hours. For repeated violations, Amazon may request additional evidence such as technical documentation or test reports.

Q5Can SpaceGoats assist with GPSR compliance for pet supplies on Amazon.es?

Yes. SpaceGoats, as an Amazon full-service agency, offers comprehensive support for GPSR compliance on the Spanish market. This includes facilitating an EU Responsible Person, coordinating Spanish translations and labeling, setting up mandatory GPSR attributes in Seller Central, Ecoembes registration, and advising on AESAN requirements for pet food. With experience across multiple EU marketplaces, SpaceGoats understands the country-specific differences and can manage the compliance process efficiently.

Q6Are there regional differences in GPSR enforcement in Spain?

Yes. Market surveillance and product safety enforcement in Spain falls under the 17 Comunidades Autonomas (Autonomous Communities) and 2 Autonomous Cities (Ceuta and Melilla). Each region has its own consumer protection authority (Direccion General de Consumo or similar) that can conduct inspections. While the basic GPSR requirements apply uniformly, inspection frequency and enforcement practices can vary regionally. Catalonia (Catalunya), Madrid, and Andalusia are considered particularly active in market surveillance.

GPSR (General Product Safety Regulation)Pet SuppliesSpain 🇪🇸

Designate EU Responsible Person (Responsable en la UE)

Conduct Product Safety and Conformity Assessment

Ensure Product Labeling and Traceability

Configure Amazon.es Seller Central GPSR Attributes

Establish Notification and Recall Procedures

Fulfill Packaging EPR and Additional Spanish Obligations

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GPSR (General Product Safety Regulation)
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