Regulation (EU) 2023/988 · applicable since 13 December 2024
Who supplied it to you, and who did you supply it to?
Every economic operator must be able to answer these two questions, years back. In a recall, the speed of that answer decides its scope and its cost.
The General Product Safety Regulation has applied since December 2024 to consumer products not covered by specific legislation. It requires an internal risk analysis, technical documentation, a responsible person in the EU and traceability along the chain.
The traceability part reads unspectacularly and is the most expensive in a crisis: without knowing which supplier delivered which batch in what quantity, you recall everything instead of the affected part.
Who is affected
- Manufacturers, importers, distributors and fulfilment providers of consumer products.
- Swiss manufacturers selling into the EU – who additionally need a responsible person in the Union.
- Online sellers and marketplace operators with duties of their own.
- Suppliers whose batch data makes their customer’s traceability possible in the first place.
What is required
- Traceability
- Be able to name upstream suppliers and business customers for the prescribed period.
- Identification
- Mark products so that batch or series remains identifiable.
- Risk analysis
- Hold an internal analysis and technical documentation.
- Responsible person
- Name a contact in the EU for products from third countries.
- Notification
- Report safety issues and initiate corrective measures.
How SCRM covers it
Supplier per article
Which supplier delivers which article since when – the basis of any trace.
Documented switches
Supplier changes with dates, so periods stay attributable.
Evidence on the article
Declarations of conformity and test reports where they will be searched for.
Recall contacts
Supplier reachability recorded and confirmed on a schedule.
Frequently asked
We only sell B2B. Does the GPSR apply?
It targets consumer products. What matters is whether the product is intended for consumers or foreseeably used by them – not your distribution tier.
How long must records be kept?
The regulation sets a multi-year period. In practice, follow the longer of the applicable periods and keep the data while the product can still be in circulation.
Is an invoice enough as evidence?
For attribution, often yes. A targeted recall needs the link to batch or series – and that is usually what is missing.
As of July 2026. Not legal advice.