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December 16, 2024

Navigating EU's New GPSR Compliance for Shopify Merchants

Starting December 13th 2024, all Shopify merchants selling to customers in Europe must comply with the EU’s General Product Safety Regulation (GPSR). This includes providing much more detailed product safety information, whether you're selling physical products or digital goods.

If you're running preorders on Shopify, it’s important to set clear expectations about your products and preorder process to stay compliant.

There isn't much information out there yet tailored for Shopify merchants (especially ones who run preorders) - so in this blog post, we share what we've learnt so far.

What Info Do You Need to Provide for GPSR?

Comprehensive Product Safety Information

Even for seemingly simple products (using books as an example below), you'll need to provide detailed safety-related documentation.

Proof of Product Safety Standards

Obtain documentation from your manufacturer demonstrating:

  • Use of non-toxic materials (e.g. Books are printed on non-toxic paper)
  • Use of approved printing inks
  • Compliance with child safety standards (e.g. No small parts hazardous to children)

Detailed Safety Documentation

Clearly explain:

  • How to use the product safely
  • Potential risks
  • Who the product is suitable (and not)
  • Any special usage instructions

Contact Information

You must provide:

  • A direct contact method for European customers
  • Someone located in the EU to be responsible for answering product safety-related questions
  • (It's unclear whether they'll strictly enforce and check if this representative is actually located in the EU)

Pre-Order Specific Requirements

For products sold through pre-orders, you'll need to state:

  • Full product details (even if they haven't been produced yet)
  • An expected delivery date
  • A clear explanation of what happens if there are potential delays

PS. Now is a good time to check out our blog article on how to set clear customer expecations for pre-orders.

Preparing for Your Shopify Store's GPSR Compliance

Now that you know what info to include to be compliant, here's how to ensure you're compliant.

Product Pages:

  • If you have a website dedicated to the EU market, we recommend you include the product safety info directly in each listing.
  • If you have one website selling worldwide, you can add the safety info in an accordion-style dropdown to minimize visual impact for everyone while EU customers can still access it.
  • You could also link to a PDF with all the details, so you're not overwhelming your customers visually.

Packaging Inserts:

  • Shipping labels are too small for detailed info, so we recommend merchants to include an info card in the packaging.
  • Include General safety info, Manufacturer and importer details, and Contact information for your EU-based Responsible Person.
  • Alternatively, you can use a document-enclosed pouch attached to the outside of the package near the shipping label. This ensures visibility for both EU customs and your customers.

Orders Placed Before December 13th 2024:

  • Orders shipping after GPSR comes into effect should still comply, just to be safe.

GPSR FAQs for Shopify Merchants

We've compiled some Q&As found on different parts of the internet. If you have the time, highly recommend you view their official Q&A doc as well.

Are any products exempt from the GPSR?

From their Article 2, the following products are specified as exempt:

  • Medicinal products (for human or veterinary usage)
  • Food and feed
  • Living animals and plants
  • Genetically-modified organisms and microorganisms
  • Plant and animal products related to their reproduction
  • Animal by-products
  • Products for plant protection
  • Travel equipment operated by a service provider for consumers’ riding purposes
  • Aircraft
  • Antiques

What if I’m not selling high-risk products like electronics?

The GPSR requires compliance across all products, even for low-risk items, like books and home decor. (Toys and children's products are considered high-risk, by the way.) The good news is, most if not all of the safety standards are likely already met by your manufacturer - just make sure you ask for the info so you can include in your packaging. (And communicate them with your customers!)

What happens to my products that already comply with the safety requirements before Dec 13th 2024?

In Article 51, it says, "Member States shall not impede the making available on the market of products covered by Directive 2001/95/EC which are in conformity with that Directive and which were placed on the market before 13 December 2024".

There has been interpretation by others who believe this means "states cannot prevent the sale of any products already complying with safety requirements of the Directive if they were available for sale before Dec 13, 2024". The Directive basically establishes safety standards.

However, it's unclear if this means:

  • Only totally new products introduced to the market after Dec 13 will be subject to the new rules, and everything prior will be grandfathered.
  • Any safety Directive-compliant stock that was listed for sale before Dec 13 will be grandfathered until they sell out and you have to restock them; also any totally new products will be subject to the new rules.

Our recommendation to merchants is to apply the new guidelines across your entire catalog.

Thanks to Shopify Forum user Artofadornment for the info.

Do I need to comply with GPSR if I’m dropshipping?

Yes, even if you don’t manufacture the products yourself, you are responsible for ensuring compliance. Just reach out to your suppliers, request for the safety documentation, then include all required information for your customers.

Do pre-orders need different documentation for GPSR compared to in-stock products?

Yes, pre-orders require extra attention. You need to provide full product details even if the product hasn’t been manufactured yet, including safety standards, an estimated delivery date, and how you'll be handling potential delays. Our Shopify preorder app Early Bird helps you set clear customer expectations and display the info prominently throughout your customer's purchase journey.

Will Shopify offer a "responsible person" located the EU as a representative for merchants?

We haven't found any info from Shopify offering this, nor do we think they will do so - because there are legal consequences to be the responsible representative.

How can I add the safety info requirements efficiently to all products across our Shopify store?

We found an app called GPSR Compliance Manager that could help. (No, we aren't affiliated with them.) It's free and manages compliance info in a bulk management way by using metaobjects.

What are other platforms besides Shopify doing?

As of the time of writing this, we haven't found any info on what Etsy and eBay are doing yet (their sellers seem to be just as confused as Shopify merchants)! Amazon though, has already introduced compliance tools like checkboxes and dedicated safety sections in their product listings.

Given Amazon, eBay and Etsy are marketplaces, they should be working on their built-in compliance and IOSS requirements. We've seen Shopify merchants mention they'll stop selling to EU via their own store, but continue selling through these marketplaces. It's worth your time keeping tabs on what Amazon's EU sellers are doing.

Final Thoughts

While there's a lot of uncertainty about the practical implications of GPSR, we recommend our Shopify merchants it's better to overprepare for compliance than risk penalties. By setting clear expectations and preparing detailed documentation, you can still confidently sell to European customers with peace of mind.

Got questions or thoughts to share? Feel free to connect with us on LinkedIn or email us at support@shopside.com.au. We'll try our best to help.

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