GPSR for imported cleaning tools: who is the responsible person

If your company sells brushes, poles, sponges or buckets made in China under its own name or trademark, European Union (EU) law treats your company as the manufacturer of those products. Because you are established in the EU, you are also the “responsible person” that Article 16 of the General Product Safety Regulation requires for every product on the market.

The General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, is the EU’s baseline safety law for consumer products that no more specific EU law covers. It has applied since 13 December 2024 (Article 52) and replaced the 2001 General Product Safety Directive. Goods placed on the market before that date in line with the old directive may still be sold (Article 51).

This guide is general information and not legal advice. The texts were checked on 12 November 2026 and can change, so confirm your own case with a product-safety lawyer or the market surveillance authority, the national body that enforces product rules, in the country where you sell.

Why non-electrical cleaning tools fall under the GPSR

The GPSR applies wherever no other EU law with the same safety objective covers a product (Article 2(1)). A deck brush, a telescopic pole, a marine sponge or a rope-handle bucket has no law of its own requiring CE marking, the EU conformity mark, so the GPSR is the main safety law for it. Electrical goods such as boat vacuums follow their own CE legislation and sit outside this guide.

The regulation covers products intended for consumers or likely to be used by them (Article 3(1)). Goods sold for professional use count too once they reach consumers, a point the Commission repeats on Access2Markets. A brush sold through a chandlery to boat owners is a consumer product.

Manufacturer, importer, distributor: which one are you?

Article 3 defines the roles. For an own-brand importer, three of them land on the same company.

The Commission’s 2025 guidelines for businesses give the example of a company that buys mugs from a producer and sells them with its own logo: that company becomes the manufacturer. A wholesaler can be manufacturer for its own brand and distributor for other brands it resells.

What Article 16 asks of the responsible person

Article 16(1) says a product may not be placed on the market unless an economic operator established in the EU is responsible for it. Through Article 4(3) of Regulation (EU) 2019/1020, that operator must:

• verify that the technical documentation exists and can be handed to authorities on request;
• give a market surveillance authority, on a reasoned request, all information needed to show the product is safe, in a language it understands;
• inform the authorities when it has reason to believe a product presents a risk;
• cooperate with them on corrective action.

Article 16(2) adds regular checks that the product matches its technical documentation and carries the identifier, contact details and instructions required by Article 9(5) to (7), with documented evidence of those checks on request. Article 16(3) requires the responsible person’s name and contact details, including postal and electronic address, on the product, its packaging, the parcel or an accompanying document.

Labelling duties

For an own-brand importer, your company’s details fill the manufacturer, importer and responsible-person lines. The Commission guidelines add that an “electronic address” means an email address or web form that lets consumers reach you directly, and that only the size of the product justifies moving information off it.

Risk analysis and technical documentation

Before placing a product on the market, the manufacturer must carry out an internal risk analysis and draw up technical documentation (Article 9(2)). At minimum it describes the product and the characteristics that matter for its safety. Where risks call for it, the file also holds the risk analysis, the solutions adopted, any test reports, and the European standards or other references applied.

Article 6 lists what the analysis must consider: design, materials, packaging, instructions, labelling, likely users including children, and whether the product could be mistaken for food or look appealing to children. For a cleaning range, typical points to consider are how a telescopic pole locks, whether a brush head can come loose, sharp edges on metal parts, and sponges in food-like shapes.

Keep the file up to date and available to authorities for 10 years after the product is placed on the market (Articles 9(3) and 11(6)). You must also be able to name your suppliers and customers for six years (Article 15(5)).

Manufacturers must publish a complaints channel, such as a phone number or email address, investigate safety complaints and keep a register of them, of recalls and of corrective measures (Article 9(11) and (12)).

Online and distance sales listings

An online offer counts as making a product available in the EU when it targets EU consumers (Article 4). Under Article 19, every listing must show clearly:

• the manufacturer’s name, registered trade name or trademark, and postal and electronic address;
• where the manufacturer is outside the EU, the responsible person’s name and addresses;
• information identifying the product, including a picture, its type and any other identifier;
• warnings and safety information in the language of the member state of sale.

This applies to your own webshop and to retailers who list your products, so send them these details with every new item.

Safety Gate and accident reporting

Safety Gate is the EU rapid alert system for dangerous non-food products. Its business portal, the Safety Business Gateway, is where companies notify authorities.

If you have reason to believe a product you placed on the market is dangerous, you must immediately take corrective action, including withdrawal or recall where needed, inform consumers, and notify the authorities through the Safety Business Gateway (Articles 9(8) and 11(8)). Other operators in the supply chain must be kept informed (Article 9(10)).

The manufacturer must also notify, without undue delay, any accident caused by the product that led to death or serious harm to someone’s health, to the authorities of the member state where it happened (Article 20(1) and (2)). Importers and distributors who learn of an accident tell the manufacturer (Article 20(3)).

Penalties

The regulation sets no fines itself. Each member state lays down penalties that must be “effective, proportionate and dissuasive” (Article 44), so the amounts depend on the country where you sell.

The United Kingdom is outside the GPSR and has its own product-safety rules, which this guide does not cover.

Checklist before the first container

• Confirm each product is a consumer product with no CE-marking law of its own.
• Confirm the factory invoices your company, which acts as manufacturer and importer.
• Complete the risk analysis for each product and record the standards applied.
• Open the technical file and set a 10-year retention date.
• Agree a type or batch number printed on each product.
• Approve labels with your name, trademark, postal address and a working email address.
• Translate warnings and instructions for every country of sale.
• Publish a complaints channel and start the register.
• Create an EU Login account for the Safety Business Gateway and name who reports accidents.
• Send retailers the Article 19 data for their listings.
• Keep supplier and customer records for each shipment for six years.

Aslan helps buyers get this paperwork right, including the EU responsible person under the GPSR. Our fees are on the pricing page. For the product side, see how to source deck brushes from China and our marine cleaning range.