Law and tax

GPSR for online sellers: what your product page must show

GPSR for online stores: what Article 19 requires on every product page, the EU responsible person, recalls, Safety Gate and fines in Bulgaria.

The CloudCart team15 min read
A cardboard box with a label of safety symbols, a small instruction leaflet and a laptop showing a product page on a light desk
In this article · 10 sections
  1. What is GPSR and when does it apply?
  2. Manufacturer, importer or distributor: what is your store's role?
  3. What must a product page show under GPSR Article 19?
  4. Who is the EU responsible person and when do you need one?
  5. How to add the safety data in CloudCart
  6. GPSR on eMAG and other marketplaces
  7. What to do with a dangerous product: withdrawal, recall and Safety Gate
  8. What are the fines for breaching GPSR in Bulgaria?
  9. GPSR checklist for every product
  10. Frequently asked questions

In short: GPSR is Regulation (EU) 2023/988 on general product safety, and it applies from December 13, 2024. An online store selling to consumers in the EU shows on every product page the manufacturer with a postal and email address, the EU responsible person when the manufacturer is outside the EU, a picture and identifier of the product, and its safety warnings in the customer's language.

This guide is for stores selling to consumers in or from Bulgaria, including foreign founders and EU cross-border sellers. It follows the regulation and the Bulgarian Consumer Protection Act, and shows where each piece of data goes in CloudCart, the Bulgarian ecommerce platform. This is not legal advice: for a product with a special risk, ask a lawyer.

What is GPSR and when does it apply?

GPSR (General Product Safety Regulation) is Regulation (EU) 2023/988 on general product safety of May 10, 2023. It applies from December 13, 2024, replaces Directive 2001/95/EC and is directly applicable in every Member State.

In Bulgaria, enforcement sits in the Consumer Protection Act (in Bulgarian, on lex.bg). Its product safety chapter has been in force since Feb 3, 2026 (State Gazette No. 13 of 2026), and the penalties in euro since Sep 24, 2026. Supervision is done by the Commission for Consumer Protection (KZP) and the sector market surveillance authorities.

Which products are covered

GPSR covers non-food consumer products, whether new, used, repaired or reconditioned (Art. 2(3)). Medicines, food, feed, living plants and animals, plant protection products and antiques are outside its scope (Art. 2(2)). A product sold "for repair" and clearly marked as such is also excluded.

For products under specific EU harmonisation legislation (where CE marking applies), GPSR covers only the risks that legislation leaves out (Art. 2(1)). CE marking does not replace the product page data: Articles 19 and 22 still apply (Art. 70(1) of the Bulgarian act).

An online offer aimed at consumers in the EU counts as making the product available on the EU market (Art. 4), wherever your company is registered.

Manufacturer, importer or distributor: what is your store's role?

Your GPSR obligations depend on where the goods come from. Most online stores are distributors that resell products bought from an EU manufacturer or importer. A store importing from outside the EU is an importer, and one selling under its own brand is the manufacturer (Art. 13(1)).

SituationGPSR roleWhat you do
You buy from a Bulgarian or EU supplier and resellDistributor (Art. 12)Check that the product has a type or batch number, manufacturer (and importer) details and instructions in the local language, and copy that data to the product page
You import from China, Turkey or another non-EU country yourselfImporter (Art. 11)Put your name and address on the product or packaging, keep the technical documentation for 10 years, run a complaints channel
You sell goods made by someone else under your own brand (private label)Manufacturer (Art. 13(1) and Art. 9)Internal risk analysis, technical documentation for 10 years, type and batch number, complaints register, instructions in Bulgarian
Dropshipping from a non-EU supplierDepends on the chainConfirm there is an EU responsible person (Art. 16). Without one, the product cannot be placed on the market (Art. 74 of the Consumer Protection Act)
You sell on eMAG or another marketplaceTrader on the marketplaceFill in the safety data in the marketplace's fields; the marketplace has its own duties under Art. 22

An importer adds its own details without covering the manufacturer's label (Art. 11(3)). Under the Bulgarian act, manufacturers and importers give the instructions and safety information in Bulgarian (Art. 71 and 72).

In dropshipping, you are the one the buyer holds responsible. How to check a supplier is covered in the guide to what dropshipping is and how to start in Bulgaria.

What must a product page show under GPSR Article 19?

Article 19 requires every online offer to show, clearly and visibly, at least four groups of information. They belong on the product page itself: data that sits only in your terms and conditions or on the box does not meet Article 19.

  1. The manufacturer. Name, registered trade name or registered trade mark, plus a postal and an email address for contact (Art. 19(a)).
  2. The EU responsible person. Only when the manufacturer is not established in the EU: name, postal and email address of the responsible person (Art. 19(b)).
  3. Product identification. A picture, the type and any other identifier: model, batch or serial number, barcode (Art. 19(c)).
  4. Warnings and safety information. Everything printed on the product, the packaging or the accompanying document, in a language consumers in the country of sale easily understand. For customers in Bulgaria that is Bulgarian (Art. 19(d)).
Article 19 dataWhat you writeWhere in CloudCart
ManufacturerName or brand, postal address, emailVendors card in the product and a "Product safety" block at the end of the description
EU responsible personName, postal address, email (if the manufacturer is outside the EU)The "Product safety" block at the end of the description
PictureA clear product photo; where useful, a photo of the label tooMedia card, the first image is the main one
Type and identifierModel, SKU, barcode (EAN), batch if anyThe SKU and Barcode fields, the product name
Warnings and instructionsThe label text in the customer's language; the instructions as a PDFThe block at the end of the description and a PDF in the Files tab

Important: copy warnings word for word from the manufacturer's label or instructions. If a translation is missing, ask the supplier for it before you publish the product. A supplier file in English is not enough for customers in Bulgaria.

Selling to other EU countries

The language under Art. 19(d) is the one set by the Member State where the product is made available. A store in Bulgaria that ships to Romania or Greece shows the warnings in Romanian or Greek for those customers. In a multilanguage store, the safety block goes into the description in each language, as described in the guide to multilanguage, multicurrency and multistore selling.

Who is the EU responsible person and when do you need one?

The responsible person is an economic operator established in the EU who answers for the product to market surveillance authorities. Article 16 says a product covered by GPSR cannot be placed on the EU market without one. Usually it is the EU manufacturer, the importer or a non-EU manufacturer's authorised representative.

In practice:

  • With an EU manufacturer, you show the manufacturer's details and no separate responsible person.
  • Goods you import yourself from outside the EU make you the importer. Your company is established in the EU, so you name yourself.
  • Goods from a non-EU supplier shipped straight to the customer need an EU responsible person. If the supplier cannot name one, do not list the product.

How to add the safety data in CloudCart

In CloudCart, the Article 19 data goes into the product editor in the catalog, using fields that already exist. The manufacturer is picked from the vendor list, the addresses and warnings sit in a block at the end of the description, and the instructions are a PDF in the Files tab.

  1. Create the manufacturer. Go to Products → Vendors and click + Add vendor. In the vendor's description, write the full name, postal address and email.
  2. Pick the manufacturer in the product. In the product editor, use the Vendors card on the right. For many products at once, select them in the product list and use the Change vendor bulk action.
  3. Add a "Product safety" block to the description. In the Details card, Description tab, add the manufacturer's addresses, the EU responsible person (if any) and label warnings at the end. Sales channels receive the Description field; a separate tab from Add new tab shows only in your store.
  4. Upload the instructions. In the Files tab of the same card, upload a PDF with the instructions and safety information. Files are shown on the product page.
  5. Use clear photos. In the Media card, the first image is the main one. Add a photo of the label with the warning symbols when they matter for safe use.
  6. Fill in the identifiers. SKU and Barcode (up to 191 characters each) for every product and variant.
  7. Check the storefront. Open the product on a phone and confirm the safety block and file are visible.

For hundreds of products, a CSV import maps the description, vendor, SKU and barcode columns to the product fields, as shown in the guide to importing products from CSV and XML. Vendors and variants are explained in the guide to product catalog management in CloudCart.

GPSR on eMAG and other marketplaces

Under GPSR a marketplace is a "provider of an online marketplace": an intermediary through which consumers conclude contracts with other traders (Art. 3(14)). When you sell on eMAG, the trader is you, and eMAG has its own duties under Article 22.

Marketplaces must:

  • register with the Safety Gate Portal and name a single point of contact for authorities and another one for consumers (Art. 22(1) and (2); Art. 76(3) of the Bulgarian act);
  • give traders fields for the manufacturer, the responsible person, the picture, the identifier and the warnings, and show them in the listing (Art. 22(9));
  • remove a listing for a dangerous product within 2 working days of an order from a surveillance authority (Art. 22(4)) and process a notice within 3 working days (Art. 22(8));

A listing without safety data can be rejected or taken down, so keep the data in the product in your store and send it from there.

What to do with a dangerous product: withdrawal, recall and Safety Gate

When a product is dangerous, the distributor immediately informs the manufacturer or importer, makes sure corrective action is taken and that the authorities are notified through the Safety Business Gateway (Art. 12(4)). A withdrawal stops a product still in the supply chain from being sold; a recall brings back a product the consumer already has (Art. 3(25) and (26)). Your Europe summarises the business side of both.

Withdrawing the product from your store

In CloudCart, turn off the Published switch in the product and save. An unpublished product is not shown to customers. For many products at once, use the Unpublish bulk action in the product list. Hide from store is not enough: a hidden product disappears from categories and search but stays reachable at its direct URL.

Recalling it from customers

Every affected customer who can be identified is informed directly and without undue delay (Art. 35(1)). In CloudCart, open Orders → Ordered Products: for each product and variant you see the numbers of the orders that contain it, and on plans with order export you can download the table as CSV. Customers you cannot reach see the notice on your site, social media and newsletter (Art. 35(4)).

A written recall notice contains (Art. 36(2)):

  1. Headline. Exactly "Product safety recall", in the language of each country where you sold the product.
  2. Product description. Picture, name and brand, batch or serial number and where to find it on the product, and when and by whom it was sold.
  3. The hazard. A clear description, without words such as "voluntary", "precautionary" or "in rare situations" that lower the sense of risk.
  4. What the customer does. An instruction to stop using the product immediately.
  5. The remedies. What the customer gets under Article 37.
  6. Contact. A phone line at no cost to the caller, or an interactive online service, for more information.
  7. Sharing. Encouragement to pass the notice on to others, where appropriate.

Under Article 37 the customer chooses between at least two of three remedies: repair, replacement with a safe product of the same type and at least the same value and quality, or a refund of at least the price paid. Only one remedy is allowed by exception, when the others are impossible or disproportionately costly, and the remedy costs the customer nothing. These rights are separate from warranty claims and the right of withdrawal, covered in the guide to the returns policy for an online store in Bulgaria.

Safety Gate (formerly RAPEX)

Safety Gate is the EU rapid alert system for dangerous non-food products, previously known as RAPEX. The public Safety Gate portal lists alerts from authorities in all Member States: before you start selling a product from a new supplier, search for its brand and model there. In Bulgaria, alerts are submitted by the Commission for Consumer Protection (in Bulgarian), the national contact point (Art. 80 of the Consumer Protection Act).

What are the fines for breaching GPSR in Bulgaria?

The penalties for GPSR breaches are set in Art. 211 to 218 of the Bulgarian Consumer Protection Act, in euro from Sep 24, 2026 (State Gazette No. 87 of 2026). Individuals get a fine; sole traders and companies a pecuniary sanction.

BreachConsumer Protection ActFine (individual)Sanction (sole trader, company)
Placing or making available a dangerous product (Art. 5 GPSR)Art. 211€3,000 to €25,000€5,000 to €30,000
Importing without instructions and information in BulgarianArt. 213(2)€600 to €1,000€1,500 to €3,000
Any other GPSR obligation of an economic operator not metArt. 215€1,500 to €4,000€3,000 to €8,000
A marketplace obligation not metArt. 216€1,500 to €6,000€3,000 to €11,000
Ignoring a KZP order on product safetyArt. 218€600 to €3,000€3,000 to €20,000

Authorities can also inspect, request documents and order a withdrawal or recall (Art. 84). Article 19 has no separate penalty in the Bulgarian act, so missing data on a product page falls under the general rule of Art. 215.

GPSR checklist for every product

Run it for every new product and supplier.

  1. Scope. The product is a consumer product and not food, medicine, feed, a plant or an antique.
  2. Role. You know whether you are the distributor, importer or manufacturer for this product.
  3. Manufacturer. Name or brand, postal and email address are in the product and in the "Product safety" block.
  4. Responsible person. For a non-EU manufacturer, an EU person with address and email is named.
  5. Identification. Photo, model or type, SKU and barcode are filled in.
  6. Warnings. The label text is in the description in each language you sell in, and the instructions are a PDF in the Files tab.
  7. Safety Gate. The brand and model are not in the alerts on dangerous products.
  8. Recall plan. You know how to find the orders with the product and who sends the notice.

Frequently asked questions

GPSR is Regulation (EU) 2023/988 on general product safety for non-food consumer products. It applies from December 13, 2024. Products placed on the market before that date that comply with the old directive can still be sold (Art. 51). In Bulgaria, the matching provisions of the Consumer Protection Act are in force from Feb 3, 2026, and the fines in euro from Sep 24, 2026.

Under Article 19: the manufacturer's name or brand with a postal and email address, the EU responsible person when the manufacturer is outside the EU, a picture, type and identifier of the product, and the warnings and safety information in the language of the country of sale. The data must be clear and visible in the offer itself.

An economic operator established in the EU who answers for the product to market surveillance authorities (Art. 16). It is usually the EU manufacturer, the importer or the authorised representative of a non-EU manufacturer. Without one, the product cannot be sold in the EU.

Yes. Article 19 has no size exemption and applies to every operator selling online to consumers. Used, repaired and reconditioned products are covered too, unless clearly marked as goods for repair.

Under Art. 22(9), eMAG as a marketplace must give traders a way to enter the Article 19 data and show it in the listing. The trader fills in the manufacturer, the EU responsible person, the identifier and the warnings; a listing without them can be rejected or removed.

Yes, if you sell to consumers in the EU. An online offer aimed at EU consumers counts as making the product available on the EU market (Art. 4), wherever your company is registered, and a product needs an EU responsible person before it can be sold.

Questions about setting up the safety data in your products? Write to support@cloudcart.com.

Sources

  1. Regulation (EU) 2023/988 on general product safetyeur-lex.europa.eu
  2. Consumer Protection Act (in Bulgarian, on lex.bg)lex.bg
  3. Safety Business Gatewaywebgate.ec.europa.eu
  4. Your Europeeuropa.eu
  5. Safety Gate portalec.europa.eu
  6. Commission for Consumer Protection (in Bulgarian)kzp.bg
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