EU GPSR Regulation: What Fashion Brands Need to Know

Why This Matters Now: On December 13, 2024, a new EU law called the General Product Safety Regulation (GPSR) comes into full effect​. For fashion brands, this isn’t just bureaucratic noise – it’s a game-changer. Recently, headlines about unsafe clothing have made waves (like a hoodie that nearly caught fire on a child​, or popular apparel found laced with toxic chemicals​), underscoring why the EU is cracking down on product safety. The GPSR introduces stricter rules and hefty penalties (up to €2 million fines or up to 5% of annual turnover) for selling dangerous products​. In short, if you’re a fashion brand selling in Europe, you need to understand what this regulation means for you – and fast.

So, what exactly is the GPSR? In a nutshell, it’s an overhaul of the EU’s product safety rules for all consumer products. It replaces the old General Product Safety Directive with tougher requirements to prevent harm and ensure traceability. That means clothing, footwear, accessories – everything you sell – must meet new safety obligations. Why should you care? Because non-compliance can seriously hurt your business. Consider the risks:

• Hefty fines & legal trouble: Regulators can impose fines in the millions for GPSR violations​.

• Blocked sales: Retailers and marketplaces will demand proof of compliance. If you can’t show you meet GPSR, you could be barred from selling on major platforms or stores​.

• Customs seizures: EU border authorities can stop or destroy shipments that don’t follow the rules, leading to lost inventory and revenue.

• Reputation damage: No brand wants to be the next safety scandal. Beyond legalities, you have a duty to your customers’ safety​. A recall or injury can wreck consumer trust.

  
  

Sound scary? It doesn’t have to be. Below, we break down the key GPSR obligations for fashion brands – in plain English – and how to tackle each one. From new labelling rules to keeping a “product safety diary,” here’s what you need to know to stay compliant and protect your customers (and your company).

Incident Reporting: Act Fast When Something Goes Wrong

Despite your best efforts, problems can still happen – a drawstring injures a child, or a batch of jackets has a hazardous chemical. Under GPSR, if you become aware of a serious safety issue with one of your products, you have explicit duties to act immediately:

• Inform authorities: You must notify EU authorities through the Safety Gate/RAPEX system as soon as you know a product you sold poses a serious risk​. This puts regulators on alert that there’s a dangerous item in the market.

  
  

• Inform customers: You also need to quickly contact all customers who bought the product​. Typically this means sending out email alerts or notices saying “This product may be unsafe – stop using it,” with guidance on next steps.

  
  

• Public recall notice: In many cases, you’ll be required to publish a recall notice (for example, on your website and perhaps in press releases or social media) to publicly announce the issue​. This spreads the word so anyone who missed the direct notification gets informed.

  
  

Think of this as a three-step recall procedure: alert the authorities, alert your customers, and alert the general public. The goal is to get the unsafe product off the market and out of people’s hands as quickly as possible. GPSR makes it clear that dragging your feet is not an option – speed can literally save lives. Make sure you have an internal plan for this (know who will draft notices, how to access customer email lists, etc.), so if an incident happens, you’re ready to respond on a moment’s notice.

Complaints Register: Track Every Issue (Even Small Ones)

Not every product issue is a headline-grabbing emergency. Small problems happen too – a customer reports a sharp edge on a buckle that scratched them, another says a kids’ sweater unravelled into a long chord. Under GPSR, you’re expected to track all safety-related complaints or incidents, even minor ones, in a Complaints Register. In practice, this is an internal log of any safety concern that comes up. It can be as simple as a spreadsheet or Google Sheet​ where you record: the date, product, issue reported, and what follow-up you did.

Why do this? It creates a “paper trail” of product issues and how you addressed them. Regulators can ask to see this log, and you’re required to keep it for 10 years​. More importantly, it helps you spot patterns – if multiple customers report the same issue, you know you have a bigger problem to fix.

A few tips for managing your complaints register:

• Log everything: Even if an issue seems trivial (e.g. one-time complaint about an itchy tag), record it. GPSR wants you to be granular and not dismiss anything​.

• Integrate customer service: Your customer support or social media team will likely hear about problems first. Instruct them to funnel any safety-related feedback into the register​. It could be as simple as having a shared spreadsheet or form they fill out for each complaint.

• Appoint a responsible person internally: GPSR actually requires that someone in your company is clearly responsible for compliance tasks like this​. It’s a good idea to designate a compliance manager (doesn’t have to be a new hire; could be an operations manager or product lead) who checks the register regularly and makes sure issues are addressed.

• Document fixes: Don’t just note the complaint – also note what you did about it. If a shoe had a sharp edge that cut someone, did you change the design or instruct the factory to correct it in production? Write that down (“corrective action taken”) in the log​. This shows that you’re not only listening but actively improving product safety.

  
  

The complaints register might feel like extra paperwork, but it’s extremely useful. It’s your early warning system for product faults and a record that you’re fulfilling your due diligence. Should regulators ever question your product’s safety, you can show this log to demonstrate how you monitor and handle issues over time.

EU Responsible Person: You Need an Address in Europe

One of the most talked-about GPSR changes is the requirement for an EU Responsible Person (often abbreviated EU RP). In plain terms, if your brand is not based in the EU (for example, a UK, US, or Chinese company), you must appoint a person or entity in the EU to take responsibility for your product’s safety compliance​. You can no longer sell directly to EU consumers on your own.

There are a couple of ways to comply with this:

• Authorized Representative: This is a company or individual in the EU that you formally designate to act on your behalf for compliance. There are professional services that do this, or it could even be an existing business partner. If you sell direct-to-consumer (e-commerce into the EU), an authorized rep is the typical solution​.

  
  

• Importer or Retailer: If you sell through an EU distributor or retailer, that partner can serve as the Responsible Person by default (since they are importing the goods)​. In this case, they take on the compliance liability – but importantly, you as the brand must still make sure their name and address appear on the product. In other words, if BigRetail Co in Germany is your distributor, BigRetail Co’s information needs to be on your labels as the EU Responsible Person, and it’s your job to put it there​.

  
  

It is prohibited for a non-EU brand to sell to EU consumers without an EU Responsible Person in place​. Think of the Responsible Person as the EU-based contact who authorities can reach out to for any product issues, compliance questions, or recalls. This entity’s name and address (and email) must be printed on each product or its packaging​. The idea is that if something goes wrong, there’s a traceable point of contact within the EU.

A few practical notes:

• You’ll need to update your product labels to include the Responsible Person’s details (more on labeling below). Typically it would say something like “EU Responsible Person: [Company Name], [Address], [Email]”.

• The info should be on the product itself whenever possible (e.g. on the sewn label or printed on the box). Only if it’s technically impossible (for instance, product too small or it would ruin the product) can it go on the packaging or an insert​. In fashion, there’s usually a care/content label where this can be added.

  
  

• This requirement has caused a rush among brands to find authorized reps or clarify distributor roles. Don’t leave it to the last minute – if you need a rep, start that process early so you have their information ready for your labels and documentation.

Labelling & Traceability: New EU Labeling Rules

Beyond the EU Responsible Person info, the GPSR brings in some new labeling requirements for products. The aim is to improve traceability – authorities want to be able to trace who made a product, and which specific product it is, if there’s a safety issue​. For fashion items, here’s what you now need to ensure:

1. Unique Product Identifier: You must have some sort of code or identifier on the product that is unique to that model or item type​. In the fashion context, this could be a SKU, style number, or barcode number that identifies the exact product variant​. It’s not enough to just have the product name like “Summer Jacket” – it should be something like “Style 1234-Blue-M” that points to the specific design, color, and size. Essentially, if a safety problem arises, you can pinpoint which product (among all your styles) is affected. Most brands already use SKU or product codes internally; now you need to make sure that code is also on the product label for traceability.

   
   

2. Brand/Manufacturer Contact Details: The label must include the name and address of the “manufacturer” – which for private labels and brands means your company (the brand owner)​. This is a key point: many small brands confuse this with listing their factory’s details. GPSR wants the responsible brand’s info (since you’re the one accountable to consumers). So, ensure your label has your brand name and a contact address. Additionally, you need to provide a way for people to reach you – either an email or a phone number or website. The regulation allows an email or website as the contact method​, but there was discussion in our webinar that an email is preferable to just a website​ (since an email is a direct line to report issues). At minimum, have something like “Made by [Brand Name], [Address], [Email or Website]” on the care label.

   
   

3. Relevant Safety Warnings: If your product has any characteristics that require a safety warning, that warning needs to be clearly provided on the product (or packaging). For example, if a children’s coat has a long drawstring, you might need a warning about strangulation risk; or “keep away from fire” warnings on flammable nightwear. This part is a bit open-ended because not all fashion items will have safety warnings – it depends on the product and the risks identified. GPSR basically says: include appropriate warnings where necessary​. We’ll talk more about how to determine what warnings are needed in the Risk Assessment section.

   
   

Another important aspect: language. Any mandatory safety warnings or instructions have to be in the official language(s) of the country where the product is sold​. Fashion products often sell across multiple EU countries, so this means you might need multi-language labels or inserts. For example, if you sell a jacket EU-wide and it has a “keep away from fire” warning, that warning should be in French, German, Italian, Spanish, etc. for all the EU markets you enter​. Many brands are surprised by this – printing 20+ languages on a small clothing label is a challenge. One workaround is using pictograms where possible (standard symbols) or including a multi-language booklet/hang-tag. The key is that an end consumer in, say, France or Poland must be able to read any safety info in their language.

Finally, no digital-only labels. GPSR explicitly states that providing information solely in electronic form (like a QR code or a website link) is not sufficient​. You can certainly add a QR code for convenience, but it cannot replace having the printed info on the product. The idea is a consumer or inspector shouldn’t have to scan something or go online to find basic identity and safety info.

To summarize the labeling changes: you’ll likely need to revamp your care labels or packaging to ensure they include (a) a unique identifier for the product, (b) your brand’s name & contact (plus the EU rep’s contact if applicable), and (c) any needed warnings in the correct languages. The primary purpose is to make every product traceable and inform consumers. Next time you print labels, double-check these elements are all there – it’s much easier to integrate it now than to relabel products later.

Risk Assessment: Prove Your Products Are Safe

Perhaps the most challenging (and time-consuming) new requirement is that every product now needs a documented risk assessment​. What does that mean? Essentially, you – the brand – must systematically analyze and document the potential safety risks of your product before selling it, and keep a record of that analysis. This is a shift from the old approach where many fashion companies assumed “clothes are harmless” and only worried about specific issues like REACH chemical compliance. GPSR makes you look holistically at each product for anything that could make it unsafe.

Here’s how you can approach risk assessments in a practical way:

Step 1: Identify applicable standards and regulations. Start by listing out existing laws, standards, or guidelines that already apply to your product category. In fashion, some common ones would be:

• The REACH Regulation (EC 1907/2006) – which restricts hazardous chemicals in products (like limits on lead, cadmium, certain dyes, etc.).

• EN 14682 – a European standard on drawstrings and cords in children’s clothing (to prevent strangulation hazards).

• The General Flammability requirements (various standards, e.g. nightwear safety standards EN 14878 for flammability).

• Regulation (EU) 1007/2011 – on textile fiber content and labeling (not a safety issue per se, but part of product compliance).

• Toy Safety Directive (2009/48/EC) – if any of your products could be considered toys or have toy-like attachments for kids.

• Packaging laws – e.g. rules on plastic bag suffocation warnings or the Packaging Waste Directive for any packaging components​.

  
  

You don’t have to reinvent the wheel; many hazards are already addressed by these existing rules. Make sure you’re meeting all of them. For instance, REACH will cover a lot of chemical hazards: if you ensure your materials pass REACH tests for banned substances, you’ve mitigated the toxic chemicals risk to a large extent​. Similarly, following the drawstring standard eliminates that strangulation hazard in kidswear by design. List all these applicable standards in your risk assessment document – it shows you did your homework on known risks.

Step 2: Identify remaining hazards. After covering the obvious stuff from known standards, think about any other potential hazards your product could pose​. In fashion, typical safety hazard categories include:

• Chemical hazards: Could any chemicals in the material be harmful? (Allergens in dyes, excessive formaldehyde, etc.) This should mostly be covered by REACH compliance, but also consider things like skin irritants or if the product is intended for babies (who have stricter limits).

• Mechanical/physical hazards: Could the product physically hurt someone? Examples: sharp edges or points (a metal zipper with a burr, a decorative stud that’s pointy)​; small parts that could detach and become a choking hazard (buttons or rhinestones on kids’ clothes); entrapment or strangulation risks (a hood cord getting caught on playground equipment)​; and even issues like a very tight garment that could impair circulation in rare cases. Think of how a child or an elderly person might interact with the product too, not just the “average” user – GPSR specifically says to consider vulnerable consumers and foreseeable use.

  
  

• Fire hazards: Is the material highly flammable in a way that could pose a risk? (Thin rayon or tulle that ignites easily, for example.) Nightwear and kids’ costumes are notorious for fire risk – if you sell those, you might need them to be flame-retardant or have clear warnings​. The slide example of the hoodie catching fire highlights this – a plastic-based fabric that melts to the skin is a fire hazard not everyone anticipates​.

For each hazard you brainstorm, note whether it’s addressed by a standard or if it’s something you need to handle specially. For instance, you might realize that a handbag has a long shoulder strap that could pose a strangulation risk for a toddler – there’s no specific “handbag strap law,” but you’d flag that as a potential hazard in your assessment.

Step 3: Mitigate the risks. It’s not enough to just identify risks; you have to show that you took steps to mitigate them. In your documentation, for each hazard you identified, write down what you did about it:

• If it’s a chemical hazard, perhaps you did a lab test on the material to verify it meets safety limits. Or you switched to a different supplier with Oeko-Tex certified fabrics.

• If it’s a choking hazard (say a button that could come off), you might implement stricter quality control in production (pull tests on buttons) or redesign to use a different attachment method.

• For a fire hazard, maybe you add a permanent label “Keep away from fire” and ensure the product passes a flammability test.

• For a sharp edge, you tweak the design (no sharp corners on a buckle) or add a safety cover.

You should also consider user instructions or warnings as mitigations. Sometimes the fix is telling the consumer about the risk so they can avoid misusing the product. For example, a child’s raincoat with a detachable belt might include a warning not to tie the belt into a loop around the neck (to avoid strangulation).

Document all these measures. GPSR expects you to do something about each risk and record it. If a risk is negligible or no different than any normal clothing, you can note that too (“Risk X is deemed low and comparable to any garment of this type”). The main point is, you’ve gone through a thinking process for safety and written it down.

Admittedly, this risk assessment requirement is a new muscle for many fashion brands. It’s more common in industries like toys or electronics. But it’s becoming the norm in apparel now too. The good news is, once you do it for one product, it gets easier to do for the next because many risks and mitigations will be similar. You can create a template for your brand. Over time, this practice can actually improve your products – you’ll catch design issues earlier and create inherently safer items.

Technical Documentation: Your Compliance Evidence File

Hand-in-hand with the risk assessment comes the need for Technical Documentation for each product. Think of technical documentation as a dossier or file that contains all the information proving your product is compliant and safe. Under GPSR, you must have this documentation ready, and store it for at least 10 years after the product is on the market​.

What goes into a technical file for a fashion product? It will include a mix of design info and proof of safety measures. A typical technical documentation file might have:

• Product identification and specs: Basic info like the product name/model, SKUs, a description, and intended use. It can include a line sheet or tech pack excerpt – e.g. “Women’s Leather Handbag, style #AB123, intended for adults, dimensions 30x20 cm” etc. Also include the materials and components (fabric composition, trims, etc.)​. Essentially, describe the product so someone reading the file understands exactly what item it is.

• Design and production info: Who made it (the manufacturer or factory), batch or lot numbers if applicable, diagrams or photos of the product, and perhaps the processes used (for instance, if it’s treated with a chemical finish, note that). This helps trace issues and is part of being able to identify the product.

• Risk assessment and test reports: Insert your risk assessment document here – all the hazards you identified and mitigations. For each mitigation that involved a test or certificate, attach the proof. For example, if you did a chemical test report for lead content or azo dyes, include that lab report in the file. If you have a certificate that your factory follows a safety standard, include it (but remember, factory social compliance certificates are not product safety proof on their own – you need actual product test results). If you performed a flammability test or a tensile strength test on a component, include those results.

• Labels and user info: Keep a copy of the actual care and content labels, any warning labels, and user instructions that come with the product. If you produce a pamphlet or even a website page with safety info, include a printout. The technical file should show that the required labels (unique ID, addresses, warnings, etc.) are present – often brands will save a PDF of the label artwork or a sample physical label.

• Complaints/incident records (if any): Over time, if you have recorded issues in your complaints register related to that product, you might attach or reference them here along with what was done (especially if it led to a design change or recall). This might not be applicable until the product has been on sale for a while, but it’s part of the living “history” of the product’s safety.

There’s no predefined format for a technical file​. You just need to have the information compiled and be able to present it on request. Many companies use a simple folder (physical or digital). For instance, you might have a folder on Google Drive for each style that contains all the above documents. Using a system with version control (like a shared drive or compliance software) is helpful. The key is that even years later, you can show regulators everything about how that product was compliant.

Organize and retain these files diligently. GPSR says you should be able to provide the technical documentation without delay if asked​. Imagine a safety authority comes to you in 2027 questioning a dress you sold in 2025 – you should still have the full paper trail to show them. This is where good digital filing and backups matter. It’s wise to designate someone (like that compliance manager) to be in charge of maintaining these docs.

One more thing: evidence of compliance is your shield. If something goes wrong and you need to defend your brand, having thorough documentation can be the difference between a quick resolution and a hefty penalty. Regulators are far more lenient if you can show you tried to comply and had all your info in order, versus a company that has no records and appears negligent. As one expert put it: the key to avoiding fines is evidence – show that you did your due diligence​.

Real-World Risks of Non-Compliance

We’ve touched on the risks throughout, but let’s spell out clearly what’s at stake if you ignore GPSR requirements or get sloppy:

• Fines and Legal Action: The law gives authorities teeth to enforce compliance. Brands can face fines up to €2 million (for smaller companies) or up to 5% of annual turnover for larger ones in serious cases​. These penalties are significantly higher than before – they’re meant to hurt. Beyond fines, in extreme negligence cases, there could even be criminal liability for company officers, but financial penalties and product bans are the main tools.

  
  

• Product Seizures & Recalls: If your product doesn’t meet the GPSR obligations (say, missing an EU address on the label or lacking a risk assessment), it can be deemed non-compliant even before an accident happens. Market surveillance authorities (and customs) have the power to stop products at the border or order them off shelves​. You could have an entire shipment impounded because documentation isn’t in order. Likewise, if an unsafe product slips through and causes harm, you’ll be forced into a recall. That means not only lost sales, but logistical costs, warehousing of returned stock, and disposal or repair costs – not to mention headaches dealing with customers and press.

  
  

• Loss of Sales Channels: Big retailers and online marketplaces are going to enforce these rules strictly on their suppliers. We’re already seeing marketplaces like Amazon requiring proof of EU Responsible Person and compliance info for certain categories. If you can’t demonstrate compliance, retailers may refuse to carry your products – they don’t want the liability or bad PR​. In effect, GPSR compliance could become a ticket to play in the EU market. No ticket, no game. It’s better to be proactive and have your “compliance binder” ready to show any potential B2B partner.

  
  

• Reputation & Brand Trust: Modern consumers are tuned into product safety. News travels fast, and a serious safety incident can break on social media within hours. If a child is hurt by your product or a watchdog group finds toxins in your fabric, you could be facing a PR crisis. Aside from the moral responsibility (you certainly don’t want to be the cause of a child’s injury or an environmental harm), the long-term trust in your brand is on the line. Brands that handle safety well can actually turn it into a positive (“we rigorously test our products”), but brands that are caught off-guard will be seen as irresponsible. GPSR is partly about accountability – it’s the EU telling brands: take responsibility for what you sell. If you don’t, you’ll face consequences. And frankly, doing the right thing by making sure your clothes won’t hurt someone is also part of building a reputable brand. No one wants to be the next headline for the wrong reasons​.

  
  

In short, non-compliance risks your money, your sales access, and your brand’s good name. The flip side is that compliance can be a competitive advantage – use it as a selling point that your brand cares about quality and safety.

Common Mistakes and Misconceptions

As fashion companies gear up for GPSR, a few common pitfalls have emerged. Avoid these, and you’ll already be ahead of the game:

• Assuming your supplier handles it. One of the biggest mistakes is thinking that your factory or supplier is taking care of all this. In reality, suppliers in places like China or Bangladesh might not even be aware of the EU GPSR (they deal with many clients, and compliance is usually driven by the brand’s demands). You, the brand, carry the legal liability, not the factory​. While a good supplier can help provide test reports or follow your instructions, don’t just ask “is this GPSR compliant?” and leave it at that – you need to know the details and likely coordinate the compliance efforts. Always double-check any info they give you (and be specific in what you ask for).

  
  

• Trusting paperwork at face value. Another trap is taking supplier-provided test reports or certificates as gospel without verification. Unfortunately, it’s not unheard of to encounter fake or outdated test reports in supply chains​. For example, a fabric mill might hand out a generic chemical test report that doesn’t actually correspond to your specific fabric lot, or a lab report that is several years old. Treat any document you get with some healthy skepticism: check dates, check that the tests cover the right regulations and the exact material. It might be worth doing spot checks by commissioning your own lab tests, especially for critical safety aspects, to be sure the results are real.

  
  

• Confusing social compliance with product safety. Many fashion brands focus on audits and certifications like BSCI, Sedex, FairTrade, etc. Those are great for ensuring ethical manufacturing, but they have nothing to do with product safety requirements​. Don’t let a factory’s ISO 9001 or SEDEX certification lull you into thinking the products are automatically safe. GPSR is about things like chemicals, physical safety, and accurate labelling – completely separate from workplace conditions. You still need to test and evaluate products regardless of factory audits.

  
  

• Neglecting to update labels/designs in time. Some brands might understand the rules but procrastinate on implementing them – for instance, planning to add the EU address later, or do risk assessments “when we have more time.” The deadline is fixed, and it’s risky to ship non-compliant inventory after that date. Also, consider product development lead times: if you have products for Spring/Summer 2025 in the pipeline, their labels and safety considerations should be GPSR-compliant now, or you’ll end up with stock that needs rework. Build compliance tasks into your product development calendar (e.g. “Week X: finalize label with EU rep info; Week Y: review risk assessment outcomes before bulk production”).

  
  

• Overlooking language requirements. As mentioned, providing information in local languages is mandatory, but it’s easy to forget if you’re used to English-only or symbols. Ensure that any cautionary info is translated appropriately​. This might mean updating packaging or inserts. It’s an upfront effort that will save you from a lot of trouble (authorities do spot-check for correct language on labels).

  
  

Being aware of these common missteps can help you sidestep them. When in doubt, consult the actual regulation text or seek expert advice – don’t rely on assumptions. It’s better to ask a “dumb question” now than to pay a fine later.

Practical Steps to Comply with GPSR

We’ve covered a lot of ground. Here’s a straightforward checklist to get your fashion brand GPSR-ready:

1. Mark the Date & Educate Your Team: Circle December 13, 2024 on your calendar – the end of the transition period​. Make sure relevant people in your company know about this (design, production, quality, customer service, etc.). A quick internal briefing on “what is GPSR and what are we changing” can get everyone on the same page.

   
   

2. Appoint an EU Responsible Person: If your business is outside the EU, decide how you will fulfill the EU Responsible Person requirement. Will you use your EU distributor or find an independent authorized representative? Start any necessary agreements now so you have an EU name/address ready to go​. If you’re an EU-based brand, congratulations – you are the responsible person by default (but you still need to ensure your name/address is on the product).

   
   

3. Audit and Update Labels: Do an audit of your current product labels and packaging. Do they have: a unique identifier, your company name & address, an email/website, and (if non-EU brand) the EU rep’s name/address? If not, redesign them to include this info​. Also, plan for any needed warning labels or icons based on your risk assessments. Work out how you’ll include multiple languages if required (you might use pictograms or multi-language booklets for long warnings). Remember, the label is often the first thing authorities check.

   
   

4. Perform Risk Assessments for Products: Gather your product list and systematically go through the risk assessment exercise for each (or each category of product). Identify hazards and document mitigations for each item​. If you have a lot of styles, prioritize those that might pose higher risks (children’s products, items with unfamiliar materials, etc.) to do first. For ongoing seasons, integrate a risk review into your product development cycle (e.g. right after a prototype is made, assess its risks when deciding final specs).

   
   

5. Test and certify where needed: Based on your risk findings, get any necessary lab tests done. For example, do chemical tests on materials for hazardous substances, especially for children’s wear. If you identified a flammability risk, do a burn test. If something needs to comply with a specific EN standard, arrange that testing or certification. Keep all the test reports handy for your technical documentation. It’s better to spend on testing now than to discover an issue after you’ve shipped product.

   
   

6. Set Up the Complaints Register Process: Create a simple complaints log (a spreadsheet or shared document is fine)​ and train your customer-facing teams to use it. Make it a standard operating procedure that any safety-related complaint – no matter how small – gets recorded with details and date. Decide who will own this register (e.g. your head of customer service logs entries, and your compliance manager reviews them weekly). This way, by the time GPSR is in force, you already have a habit of recording issues.

   
   

7. Plan for Incident Reporting (Recall Plan): Hopefully you’ll never need it, but prepare a basic recall/incident response plan. This could be a short document that says “if we discover a serious safety problem, X person will submit the Safety Gate report, Y person will draft customer notifications, Z will handle public communication.” Have a draft template for a recall notice ready. Know the website for Safety Gate (the EU portal) and the process to report​. When you’re prepared, you won’t panic or fumble if something happens.

   
   

8. Compile Technical Documentation Folders: Start building a compliance folder for each product style. Include the product spec, materials info, risk assessment, test reports, supplier declarations, copy of labels, etc. If you already have tech packs and testing PDFs, great – gather them in one place. Ensure these folders (digital or physical) are backed up and can be retrieved even years later. This is your evidence chest – treat it as importantly as your financial records.

   
   

9. Stay Updated: Compliance isn’t a one-and-done task. Keep an eye on updates in EU regulations. GPSR is part of a bigger movement (for example, the EU is also updating its Product Liability Directive, which could affect insurance and legal claims​). Subscribe to industry newsletters or join a compliance forum so you hear about changes. Also, feedback from your complaints register or testing might reveal new issues – use that to continuously improve your designs and processes.

   
   

Taking these steps will put you on solid footing for GPSR. It might feel like extra work (and it is), but it becomes routine once you build it into your operations. Many brands find that after implementing these compliance steps, their overall product quality improves – because you end up catching issues early and setting higher standards for suppliers and designs.

Finally, remember that compliance is an ongoing commitment, not just a deadline. By embedding safety and compliance into your brand culture, you won’t just tick a legal box – you’ll likely produce better products and earn customer trust.

In an era of increasing accountability, taking product compliance seriously is not just about avoiding fines; it’s part of good brand stewardship. Brands that adapt to the GPSR will not only steer clear of trouble but can also proudly say to their customers, “We put your safety first.” The EU GPSR is raising the bar for everyone – by following the steps above, even a small or mid-sized fashion brand can confidently meet the challenge and continue delivering great products to happy (and safe) customers.​