GPSR Compliance for Packaging Exporters to the European Union
Regulation (EU) 2023/988 — the General Product Safety Regulation — has applied to products placed on the European market since 13 December 2024. For any business exporting physical goods into the EU, including packaging, it is now a baseline legal requirement rather than a nice-to-have.
Many Chinese manufacturers still treat this as a paperwork problem to be solved at the last minute. It is more useful to understand what it actually requires.
What the regulation covers
GPSR applies to products made available on the EU market, whether they are produced inside or outside the EU. It requires that products are safe, that they are accompanied by specific information, and that there is a clearly identifiable economic operator responsible for EU compliance.
For packaging suppliers, three requirements matter most.
A responsible economic operator in the EU. Someone must be established within the European Union and reachable. This cannot be your Shenzhen factory acting through a forwarding agent’s name. If your packaging arrives and an EU consumer raises a question, there must be an entity they can contact.
Traceability. The product must be identifiable. Batches, materials and the parties involved in supply need to be documented so a problem can be traced back to its origin.
Technical documentation. This includes manufacturer identification, a description of the product and its materials, and safety information. For packaging, this typically means material composition and any relevant chemical or migration information.
Why packaging specifically comes up
Packaging is covered because it may come into contact with food, come into contact with children, or present a suffocation or sharp-edge hazard. A non-compliant box can be pulled from a European warehouse, and the cost falls not only on the packaging supplier but on the brand whose product was inside.
The most common failure points we see:
- Missing EU responsible party information. The brand’s packaging states only a Chinese manufacturer and an Alibaba contact.
- Material declarations that do not match reality. The paper certificate covers the board, but the ink, adhesive and coating were never assessed.
- No batch linkage. When a complaint arrives, there is no way to identify which production run the affected boxes came from.
What to ask your packaging supplier
Do you support GPSR documentation? Not “are you compliant” but “what do you provide.” A useful answer names the specific documents.
Can you provide material composition data? For each component — board, ink, adhesive, coating, lamination film.
Do you keep batch records? Linking production runs to material certificates and quality readings.
Have you shipped into the EU recently? Experience with the actual requirements rather than theoretical knowledge.
Will you sign a declaration? Many importers require a written declaration of conformity covering the packaging itself.
What we provide
For orders shipping into the EU, we supply a documentation package that typically includes:
- Material composition declaration covering board, ink, adhesive and finishing
- FSC chain-of-custody certificate number where FSC material is used
- RoHS conformance statement where applicable
- Batch traceability records linking the shipment to its production run
- Manufacturing identification and facility details
We do this as standard for EU-bound orders because the alternative is a shipment that gets held while someone reconstructs information that should have existed at production time.
Practical advice
Do not treat GPSR as a customs problem. Customs will generally let the shipment through and it will be stopped later, at a warehouse or during a market surveillance check, at which point the cost is significantly higher.
Build the documentation into the production run rather than assembling it after the fact. If your current packaging supplier cannot tell you what documentation they provide for EU shipments, that is a useful signal about how many other EU-bound shipments they have handled.
And if you are a brand shipping into the EU, make sure your own economic operator obligations are met. Your packaging supplier’s documentation supports your compliance; it does not replace it.
