Product traceability under GPSR: what a small shop has to record

The General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) has applied since 13 December 2024. It replaced the old General Product Safety Directive and covers almost every non-food product sold to consumers in the EU, in a shop or online. Products with their own rules (toys, cosmetics, electrical goods and others) still follow those, and the GPSR covers what they leave out.

Most of the news was about online marketplaces, but the rules reach the small shop too. If you sell products to consumers, the GPSR has duties for you, and if you make or import them, it has more.

Which role you have

The duties depend on what you do with each product:

• Manufacturer: you make the product, or have it made and sell it under your own name or brand. A workshop that makes furniture, candles or cosmetics is a manufacturer.
• Importer: you bring the product into the EU from outside it.
• Distributor: you buy the product from another business and sell it on. Most shops are distributors.

One business can be all three. A shop that sells branded goods and also puts together gift boxes under its own name is a distributor for the first and a manufacturer for the second.

What you need to be able to answer

Who supplied you, and which business you supplied

Every business in the chain must be able to tell the authorities, when they ask, which business supplied it with a product and which business it supplied the product to. That information has to be available for six years (Article 18).

For a shop that only sells to consumers, the first half is the one that matters: for every product, know which supplier it came from. In practice that means keeping your purchases, with the supplier and what each delivery contained.

How the product is identified

Manufacturers must put a type, batch or serial number, or something else that identifies the product, on the product itself, or on the packaging when it doesn't fit (Article 9). Distributors must check that it is there, together with the manufacturer's name and contact details, before selling (Article 11). Online, the listing must show the same information, along with any warnings (Article 19).

When a product carries a batch or serial number, it's worth recording it as it comes in. It's what a recall will ask about.

Who bought it, when that matters

The GPSR doesn't ask a shop to record which consumer bought what. But when a product is recalled, businesses must contact the affected consumers directly wherever they can, using the customer details they already hold (Articles 35 and 36). Knowing which customer bought which lot or serial lets you call five people instead of hoping they see a notice.

A recall, step by step

Say a supplier writes to tell you that lot L-2611 of a soap you sell may be unsafe. You need to answer three questions quickly:

1. Did that lot ever reach us?
2. How much of it is still here, and where?
3. Who bought units from it?

Without records, the answers are in delivery notes and receipts, checked one by one. With them, you open the lot and see it: where it came from, every move, and each sale.

While you work it out, stop selling what's affected. If you think a product you sell is dangerous, you must also tell the manufacturer or importer and the authorities, which you can do through the EU's Safety Business Gateway.

Keeping these records without extra work

You don't need a separate register. The records come from what you already do every day, as long as your stock tool keeps them:

• Record every purchase with its supplier. Receiving a purchase in Binhop keeps the supplier, the date and what arrived, in a history that is never deleted.
• Track lots or serial numbers only where they exist. Turn tracking on item by item: batches with expiry dates for cosmetics, supplements or batteries; serial numbers or IMEIs for phones, tools and appliances. Everything else works as before.
• Receive by scanning. Type a lot's number and date once, or scan serials one after another as the boxes are opened.
• Sell with a customer name when you have one. It is what lets you call them.
• If you make things, record what went into them. When a product is made from materials that have lots, Binhop records which material lots went into which batch.

Then a recall is one search: open the lot or the serial number and see where it came from and where it went. See how lot and serial tracking works.

Checklist

• Know whether you are a manufacturer, importer or distributor for each product line.
• Keep each purchase with its supplier, for at least six years.
• Before selling, check that products show a type, batch or serial number and the manufacturer's contact details.
• Online, show the manufacturer's details, how the product is identified and its warnings in each listing.
• Make sure each product you sell has a business established in the EU responsible for it (Article 16).
• Record lots or serial numbers for the products that carry them.
• Know how you would find who bought a recalled lot.

The full text is on EUR-Lex: Regulation (EU) 2023/988.