TEYING BUYER GUIDE · UPDATED OCTOBER 1, 2026
GPSR for Jewellery: What Your EU Customers Need From You in 2026
Since 13 December 2024, jewellery offered to EU consumers needs an economic operator established in the EU who carries the responsible person duties, with a name, postal address and email visible on the product or packaging and in the listing. This covers who carries which duty, what the German ProdSG adds from 19 February 2026, and what a factory can supply for the technical file.
The short answer: an EU contact, a label, and a file that lasts ten years
Since 13 December 2024, jewellery offered to EU consumers needs an economic operator established in the EU who carries the responsible person duties. That operator's name, postal address and email must appear on the product or its packaging and in the online listing. Instructions and warnings go in the language of the country of sale. The technical documentation stays available to authorities for ten years.
General guidance as of October 2026, not legal advice. Confirm your own position with counsel or your responsible person.
What the GPSR covers, and what it leaves to other rules
Regulation (EU) 2023/988, the General Product Safety Regulation, has applied since 13 December 2024 and replaced the General Product Safety Directive 2001/95/EC. It covers non-food consumer products, fashion and fine jewellery included, whether the seller sits in the EU or outside it.
Two boundaries matter for jewellery brands.
- Chemical limits are not in the GPSR. Lead, cadmium and nickel sit in REACH Annex XVII entries 63, 23 and 27. The GPSR asks for a documented safety assessment; REACH sets the numbers that assessment works against.
- The timing rule is about placing on the market, not about selling through. Stock that was already placed on the EU market before 13 December 2024 may continue to be made available. Every new production run offered after that date follows the current rules.
Offering a product on a website that targets EU consumers counts as placing it on the market, which is why the obligations reach a US or Chinese seller with no EU address.
Who carries which duty
| Party | Core duties | Where to look |
|---|---|---|
| Manufacturer | Risk analysis and technical documentation kept ten years, batch or type marking, name and postal and electronic address on the product, instructions in the language of sale, corrective action and accident notification | Article 9 |
| Importer | Place only compliant products, add its own name and address, keep a copy of the technical documentation and keep it available to authorities | Article 11 |
| Responsible person | Check the product against the technical documentation, check the identification and labelling, give authorities documented evidence on request, cooperate on corrective action | Article 16 |
| Distance seller | Show manufacturer details plus responsible person details in the offer, with a product picture and any warning text | Article 19 |
| Online marketplace | Provide a contact point, register in Safety Gate, keep interfaces that let sellers display the required information, act on removal orders | Article 22 |
A brand is rarely only one of these. A small label that designs in the US, manufactures in China and ships from a third-party warehouse can be manufacturer, importer and distance seller for the same order, and each role carries its own paperwork.
The details that have to be visible
Article 19 lists what an online offer must show, and the Commission's own guidance is clear that the two address blocks are cumulative. The manufacturer's name and contact details always appear, and the responsible person's details are shown in addition whenever the manufacturer is outside the EU. A listing that names a factory in Zhejiang with no EU operator behind it does not satisfy the article.
The required set:
- Name of the manufacturer, or its registered trade name or trademark
- Postal address and electronic address of the manufacturer
- Name, postal address and electronic address of the EU responsible person
- Information identifying the product, including a picture, type and other identifiers
- Any warning or safety information that applies to the product
The same details belong on the product itself, and where that is not possible, on the packaging or an accompanying document. A jewellery card or insert counts as an accompanying document; a bare polybag does not.
Warnings in the language of the country of sale
The GPSR leaves language to each member state. Germany has now made its position explicit. The revised Produktsicherheitsgesetz was published on 5 February 2026 and came into force on 19 February 2026, and section 6 requires German for the instructions and safety information a manufacturer must provide, the information an importer must ensure, the warnings shown in distance sales, information supplied in electronic form, and warnings displayed on online marketplaces.
In practice, an English-only insert card is not enough for a German listing, and the same logic travels: Dutch for the Netherlands, Polish for Poland. Products intended exclusively for export are outside the German requirement, which is a narrow exception rather than a general one.
The technical file, and the ten-year clock
The technical documentation is the manufacturer's internal file, and the GPSR does not require it to be published or handed to the buyer. It does have to exist, stay current, and be producible on request. A useful file for a jewellery SKU holds:
- A general description and the safety-relevant characteristics: base material, plating route and thickness, stones, findings, chain pull strength, small-part detachment
- The risk analysis, including who the product is for and how it could be misused, since jewellery resembles a small part that children can put in the mouth
- The standards or solutions applied, for example EN 1811:2023 where nickel release is relevant
- Test reports and their results, tied to the SKU and production batch
Keep it for ten years after the product is placed on the market, and note that the importer holds a copy as well. When an item is restocked from a new plating bath or a new stone supplier, the file follows the change.
What a factory can give you, and what it cannot
A factory supplies the inputs: material and finish per SKU, plating route and thickness range, stone type and setting, and the test or material documentation that applies to the order. At TEYING, that is confirmed by material, destination market and order scope, and stated in the quotation so the description on your invoice, listing and file all match.
What a factory cannot do is become your responsible person. The role requires an economic operator established in the EU, and a manufacturer based outside it does not qualify. Buying a test report from a supplier is not the same as having a compliant technical file either, because the risk analysis is yours to own.
If you are building a batch for the EU and need the material, plating and documentation inputs that go into the file, send the reference and quantity through the TEYING quote form.
FAQ
Does the GPSR apply to jewellery sold on Etsy, Shopify or Amazon into the EU?
Yes. Distance selling to EU consumers counts as placing the product on the market, and Article 19 requires the offer to show both the manufacturer's details and, where the manufacturer is outside the EU, the responsible person's name, postal address and email. Marketplaces carry their own duties under Article 22.
Can my Chinese factory be my EU responsible person?
No. Article 16 requires an economic operator established in the EU, which is normally the EU importer, an authorised representative appointed in writing, or a fulfilment service provider. A factory outside the EU can supply the technical inputs, but its name in the listing does not satisfy the requirement.
How long do I keep the GPSR documentation?
Ten years from the date the product is placed on the market, updated when the product changes. The manufacturer holds the original file and the importer keeps a copy, both producible to market surveillance authorities without delay.
Is there a GPSR certificate I can buy for a jewellery design?
There is no GPSR certificate. Compliance is shown through the technical documentation, the risk analysis and the applicable test reports, plus the labelling and the responsible person details. A supplier offering a "GPSR certificate" for a design is selling a document that has no standing in the regulation.
Building the GPSR technical file for a design?
Send the SKU list and EU markets; material, plating and documentation inputs are confirmed per project.
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