General product safety

Manufacturers in both textiles and plastics industries are responsible for ensuring that products are safe under normal and foreseeable use.

• Risk Assessment: For textiles, this might include evaluating risks related to skin contact with chemicals (e.g., azo dyes or formaldehyde) or flammability. For plastics, risks could include unsafe levels of phthalates or BPA in consumer items.
• Product Traceability and Labeling: Manufacturers must label products with clear traceable identifiers, such as batch numbers, and include contact details within the EU.
• Digital Product Information: Where relevant, digital instructions or QR-code-accessible safety info must be provided.

Example – Textile Industry: A clothing manufacturer using synthetic dyes must ensure that garments, especially for children, do not contain prohibited carcinogenic substances. If test results show unacceptable levels of restricted chemicals, the company must notify authorities and initiate a recall — potentially including retailers and online marketplaces.

Example – Plastics Converting: A producer of plastic food containers must verify that raw materials are compliant with EU migration limits for food contact. If a batch of containers leaches excessive chemicals into food during normal use, this becomes a reportable hazard under the GPSR, requiring urgent corrective action.

Importers and distributors are now equally responsible for verifying the safety and regulatory compliance of the products they handle.

• Importers must check that third-country manufacturers have followed EU safety standards, completed technical documentation, and applied appropriate labeling (e.g., CE marking, warnings).
• Distributors must verify that products bear required markings and safety information before placing them on the market and that no safety alerts have been issued.

Example – Textile Industry: An importer bringing in non-EU garments must verify that garments do not contain banned azo dyes or nickel-containing accessories. If such products are later found to cause allergic reactions, both the importer and distributor may face recall and liability obligations.

Example – Plastics Industry: A distributor of plastic toys must ensure they meet EU safety standards for mechanical parts and chemical composition. If a toy with sharp edges or excessive DEHP content is discovered, the distributor may be held responsible if they failed to verify compliance.

Retailers — particularly online platforms — now have enhanced responsibilities:

• They must act on safety notices by quickly removing dangerous products.
• They must ensure that third-country sellers have appointed an EU responsible person to guarantee traceability.
• Platforms must facilitate direct communication between consumers and product suppliers.

Example – Online Textile Retailer: A marketplace selling children’s pajamas from third-party sellers must ensure listings clearly identify the EU-responsible party. If the pajamas are later found to be highly flammable, the platform must promptly remove listings, inform consumers, and cooperate with market surveillance authorities.

Example – Online Plastics Goods Retailer: An online seller offering plastic water bottles must respond quickly to safety alerts — such as if the bottles degrade under sunlight and release microplastics into drinking water — and ensure all listings come from traceable, compliant manufacturers.

In some cases, service providers in these industries may alter products in ways that introduce new safety risks — making them subject to the GPSR.

• Customization or repair services that change a product’s functionality or material composition may be considered a new "manufacturer" under the law.

Example – Textile Services: A business offering flame-retardant treatment for curtains used in public buildings must ensure that the chemicals used are both effective and compliant with REACH and other EU safety standards. Incorrect application or mislabeling can create liability under GPSR.

Example – Plastic Component Finishing: A company that modifies plastic housings for electrical products (e.g., drill casings) through CNC machining or chemical treatments must assess whether those changes compromise the product’s safety performance.