For years, product safety regulation in the EU was the manufacturer's problem. If a non-compliant product reached a consumer, enforcement fell on the economic operator who placed it on the market. Marketplaces, Amazon, eBay, Etsy, Kaufland, Bol.com , argued they were mere intermediaries. Platforms, not traders.
GPSR changes that equation fundamentally. For online sellers who rely on these platforms to reach customers, the implications are immediate and commercial.
The new legal reality for marketplaces
Under Article 22 of the GPSR, online marketplaces have explicit obligations. They are not passive channels. The regulation requires them to:
Designate a single point of contact
For member state authorities to communicate about product safety issues.
Register on the Safety Gate portal
And have processes for receiving and acting on product safety orders and notifications.
Remove non-compliant listings
Within a defined timeframe when notified by authorities or when they become aware of non-compliance.
Cooperate with market surveillance
Including providing information about sellers and product listings upon request.
But that's the legal minimum. The commercial reality goes further. Because marketplaces now face regulatory exposure from non-compliant products on their platforms, they have a powerful incentive to proactively verify seller compliance data, and to suspend sellers who can't provide it.
What's already happening
If you sell on European marketplaces, you've likely already seen the early signs:
Amazon: Product Compliance Portal
Amazon has been the most aggressive. Their Product Compliance Portal now requires sellers to upload compliance documentation including Declarations of Conformity, test reports, and identification of the responsible person for the EU market. Products without this data are being flagged, and in many cases, listings are being suppressed automatically.
Amazon has also introduced compliance verification checks where they request specific documents for specific ASINs. Sellers who can't produce the documents within the specified timeframe face listing suspension. The automated systems don't distinguish between “I don't have this document” and “I have it but it's in a folder somewhere and I need two days to find it.” Both result in the same outcome.
eBay: Product safety and GPSR requirements
eBay has updated its seller requirements to explicitly reference GPSR obligations. Sellers are now expected to provide responsible person information in their listings and have compliance documentation available on request. eBay has been building its internal product safety infrastructure and has started using it to identify high-risk listings.
Kaufland, Bol.com, and regional marketplaces
European-focused marketplaces have been faster to implement GPSR requirements than global platforms. Kaufland's marketplace now requires compliance attributes in product listings. Bol.com has introduced mandatory product safety fields. These platforms don't have the infrastructure to do deep document verification yet, but they're building it , and they're starting with the categories that carry the most risk: toys, electronics, and children's products.
The three enforcement waves
Marketplace enforcement doesn't arrive all at once. It comes in waves, each more demanding than the last:
Marketplaces require you to fill in compliance-related fields in your product listings: responsible person name and address, CE marking status, applicable warnings. This is the low-hanging fruit, structured data fields that can be validated automatically. If you’re selling on Amazon or Kaufland and haven’t filled these in, you’re already at risk of suppression.
Marketplaces start requesting actual documents: the Declaration of Conformity, test reports, safety data sheets. Some do this proactively (Amazon’s compliance requests), some do it reactively (when a complaint triggers a review). But the trend is clear: assertions will no longer suffice. You’ll need to produce evidence.
Marketplaces build systems to track document validity over time: expiration dates, version changes, regulatory updates. Products with expired documentation get flagged automatically. The burden is keeping documentation current, not just getting it right once.
Why this changes the math for online sellers
Before marketplace enforcement, the compliance calculus was:
“The chance of a market surveillance authority auditing my specific products is low. The cost of compliance is high. The economically rational choice is to do the minimum.”
That calculation assumed enforcement came from government authorities with limited resources. It was, frankly, accurate for many sellers, market surveillance in most EU member states is chronically underfunded and can only sample a tiny fraction of products on the market.
Marketplace enforcement changes the equation because:
- It's automated.Amazon doesn't need to hire inspectors. They can flag every listing that's missing a compliance attribute or document with a database query.
- It's immediate. A listing suspension happens now. Not after months of correspondence with an authority. Now.
- It affects revenue directly. A suppressed listing means zero sales for that product on that channel. For sellers whose primary channel is Amazon, a compliance block on their top-selling ASINs is a revenue emergency.
- It's cascading.A compliance failure on one marketplace often signals exposure on others. If you can't produce documents for Amazon, you probably can't produce them for eBay either.
The documentation speed problem
When Amazon sends a compliance request for a specific ASIN, you typically have a limited window to respond with the required documents. This creates a very specific operational challenge:
The 48-hour test
Can you produce a valid Declaration of Conformity, the applicable test report, and the responsible person identification for any product in your catalog within 48 hours?
If you can't, for anyproduct, that's a listing suspension waiting to happen. Not a hypothetical risk. An operational gap that a compliance request will expose.
The online sellers who survive marketplace enforcement aren't necessarily the ones with the most thorough compliance programs. They're the ones who can find and produce documentation quickly. Speed of access matters as much as completeness of evidence.
Preparing for enforcement: a practical checklist
Here's what online sellers should do now, not eventually, now, to prepare for the enforcement wave that's already rolling:
1. Audit your highest-risk products first
Start with the products most likely to trigger a compliance request: children's products, electrical and electronic equipment, products with chemical safety requirements (cosmetics, textiles with skin contact), and your highest-selling ASINs (because marketplaces sample high-volume listings first).
For each product: can you produce the DoC, test report, and responsible person information? Is the DoC current and specific to the product you're actually selling (not a similar model)? Does the test report cover the standards required for the EU market?
2. Close the document-to-product gap
The most common failure mode isn't “we don't have the documents.” It's “we have the documents but can't link them to the specific product fast enough.” This is a data management problem, not a compliance knowledge problem.
Every compliance document in your possession should be linked to the specific product(s) it covers, with clear version tracking. When a marketplace asks for the DoC for SKU EL-1155, you shouldn't have to open five PDFs to figure out which one applies.
3. Establish a responsible person for every product
GPSR requires every product on the EU market to have an identified responsible person (manufacturer, importer, or authorized representative) established in the EU. If you're the importer, that's you. If you rely on the manufacturer or a third-party EU rep, you need documentation confirming that appointment, per product, not just as a general arrangement.
4. Build compliance data into your listing workflow
Compliance data shouldn't be an afterthought bolted onto product listings. It should be part of the listing creation workflow: no product goes live until the compliance record is reviewed and the required marketplace fields are populated from verified source data.
This is where most sellers are weakest. The compliance team (if there is one) operates independently from the listing team. Documents get collected months after a product starts selling. By the time a marketplace asks for proof, the gap between what you're selling and what you can document has grown into a liability.
5. Prepare for ongoing verification, not one-time compliance
Documents expire. Regulations get updated. Standards change. A product that was compliant when you started selling it may not be compliant two years later. Build a system that tracks document validity and alerts you to expirations, before a marketplace does it for you by suspending the listing.
The competitive advantage of compliance readiness
Marketplace enforcement creates a competitive advantage for online sellers who are prepared. As non-compliant competitors get their listings suspended, sellers with proper documentation maintain availability and gain market share.
We've already seen this pattern in categories where Amazon runs aggressive compliance verification: the sellers who invested in documentation early saw their competitors disappear from search results, leaving them with higher visibility and lower CPCs.
Compliance isn't just a cost of doing business. In a market where enforcement is tightening, it's a barrier to entry that protects compliant online sellers from undercutting by those who cut corners.
How Telden helps you stay ahead
Telden Product Service Desk is built for exactly this operational reality:
- Every SKU gets a structured compliance dossier with linked evidence, so you can produce documentation for any product in minutes, not days.
- AI extraction turns supplier PDFs into structured data, manufacturer entities, CE data, warnings, test standards, with source provenance.
- Review-by-exception workflow means compliant products flow through while you focus attention on the 20% that need human decisions.
- Multi-format publishing generates the safety pages, PDFs, and structured data that marketplaces require, from a single approved source.
- Audit trails prove who reviewed what, when, and based on which evidence, the documentation that authorities and marketplaces want to see.
The enforcement wave is here. The sellers who survive it are the ones who can produce compliance evidence for any product, on any channel, within hours.
Telden gives you that capability. Import your catalog, attach your supplier documents, and build auditable compliance records before the next marketplace request arrives.