GPSR Compliance

[bojangled]

This is as clear as mud to me. Been to the gov. advice website and various others.
How does a 1972 poster fit in to this process?

It's not an exempt category. 

Advise buyers this item is for viewing only ? 

My initial reaction, sadly, to to switch EU and NI off. 
Jo

[a45heaven]

Whilst most of my sales are / were UK based, i stopped all overseas and Northern Ireland listings as ebay provided less than minimal help in this change on GSPR.

Other platforms provided much more assistance and solutions, hence thats where i continue to perform my overseas business.

[superchallenge]

I am so confused.

I've had one sale from the EU since the GSPR came in back in December. Exactly as expected, as I made no changes and provided no GSPR info. For reference, I was previously doing about 30 a week.

I've signed up with Webinterpret, who provide GSPR compliance, but you have to add the data to each item manually. I've updated ONE item - Falcata for the PlayStation - and published via Webinterpret. My friend in Finland, with his address correctly set as being based in Finland, sees it in the search as below. The new GSPR Responsible Person/Manufacturer info shows on the listing. All good.

But then, just for a test, I thought I'd get him to search for an item that I have made no changes to - Doraemon 2 for the Super Famicom - and which has NO GSPR information attached.

He's able to go in and purchase that item without issue, seemingly.

So...I don't know what's happening.

1) If my items don't have GSPR info, why do they show to EU customers to buy?
2) If my items ARE still showing to EU-based customers, which they evidently are, then why have I only had 1 EU sale in three months, down from 30 a week?

Maybe I'm being thick, but I just don't understand it.

[houseoftheyuccas]

If they aren't new items and have previously sold in the EU you don't need GPSR compliance

[superchallenge]

The problem is that they haven't previously sold in the EU.

They were made and sold before the GSPR deadline, but only in Japan. They're imported retro video games that were for the Japanese market only.

Then again, when I said that to eBay, they had no idea if that meant they needed GSPR documentation or not. Either way, my sales from the EU and NI are non-existent (barring one) since December 13th.

[bzmotman]

I've got a private account registered on Ebay Germany so I thought I would have a quick look. I was using a German address and everything seemed OK but I couldn't see your LUCID number which might impact visibility in Germany.

There is an exemption under GPSR for certain collectors items & antiques which I rely on. As you probably know Ebay have put "I certify that all my selling activities will comply with all EU laws and regulations." on all listings. My guess is that they will let listings appear then if anything goes wrong they will rely on the comply phrase to try and shift the blame/liability on to the seller. 

In the GPSR disclosures section there is the opportunity to make an additional disclosure. That is the only disclosure I make where I state that GPSR does not apply because It is an antique as defined in Annex IX of the VAT Directive or It is a collectors item of sufficient interest to justify collecting.

I have no idea whether that is effective but I make 20 or so sales per week to the EU so it might be worth a try.

Sorry I can't be more helpful.

[showpiece-antiques]

Anything and everything is collected by anyone, so it's a collectable 😅

[showpiece-antiques]

The fact that there are millions of things for sale on ebay, and any other second hand or vintage website just shows no one is paying attention to it 

[showpiece-antiques]

Not killed it yet, as no one cares two hoots about it

[showpiece-antiques]

no, and I doubt they ever will

[action-figure-supplies-uk]

I've started selling to Northern Ireland again as I believe The Windsor Framework takes precedent over the GPSR but I've not found any information to confirm this anywhere. Only sold 1 item so far but it seemed to go ok.

And for those saying the item was "available for sale before the 13th December 2024" and that exempts the item, it doesn't.

"The concept of making available refers to each individual product, not to a type of product, and whether it was manufactured as an individual unit or in series." and "Some products outside the EU can be bought directly by end-users in the EU online or through other means of distance sales. Although these products are deemed to be made available in the Union prior to any transaction for the purposes of checks by market surveillance authorities pursuant to Regulation (EU) 2019/1020, they are placed on the market at the moment an order by an end user has been placed and confirmed for a specific product already manufactured and subject of the transaction, and ready to be shipped."

[20thcenturyglass-shop]

One thing I still don't really understand about all this - how does anyone at an EU customs actually know if the sender of a parcel has complied with these regulations? For instance I use Royal Mail Click and Drop, and there is nowhere to enter any details about GPSR exemptions or a Responsible Person etc. Are we expecting them to look up the ebay listing for these details, and if so how would they even find the listing?

[carogojo]

I agree. How do they even know the parcel is ebay-related ? One wonders
how this scheme can possibly work.



Roger Johnstone

[billythecardy]

You are responsible for including the GPSR info in the parcel with the goods, so any relevant safety information and manufacturer details in the language of the country you are selling into. And you would need to include the contact details of your EU Authorised Responsible person in the parcel too.

I've been doing this for a couple of months now and it's really not that big a faff. I have a template set up for the type of goods I sell into the EU (all paper products, so low-risk anyway) and just use google translate for whatever country I need.  I then use a label to stick the relevant manufacturer / publisher info onto my template sheet. Takes about 5 mins, which will come down as I have more countries ready set-up.  I stick a bit on the price of shipping to the EU to compensate for the time to do the extra paperwork.

It's too early to tell if it will be worthwhile to continue with this once my initial year with my EU Rep is up, but sales to the EU are definitely up on what they were before GPSR came into force, probably due to lack of competition as other sellers have pulled the plug.

[billythecardy]

They'll know because of the Digital Customs Data that is transmitted to them by Royal Mail. 

That would tell them it's through eBay because eBay will have collected the VAT. 

If they open your parcel (which they are allowed to do) they will be able to see if you have included the correct paperwork.  If you haven't then, at the very least, they're probably not sending your parcel onwards.  It's going to be random checks so you might be lucky and never get checked, but is that anyway to run a business?  Is it worth the risk?   I guess they will probably have categories of high-risk items that they will focus on (electronics?) and other lower-risk categories (like books?) will have fewer checks. 

[20thcenturyglass-shop]

Yes I understand about including info inside the parcel, but what I mean is, how would a parcel ever get stopped or returned to sender if the info was missing? How would customs ever know, when there is nowhere in the customs forms etc to mention anything about it? At what point does something get flagged for non-compliance? How is it all enforced?

[20thcenturyglass-shop]

Sorry last post was made before I saw your latest...I'm pretty sure what I sell is exempt, but it just got me wondering.

[trafton.-47]

That's only one way of doing it. It's perfectly acceptable to reference
your website and include the EUAR's details there. This has the advantage
of allowing youthem to be changed easily if, for eg, the AR's contact
details change or if you change to another AR. Otherwise, a change to the
AR would mean you'll have to sticker all your existing stock.

For the books we produce there's a standard format:

"For details of [company name]'s EU Authorised Representative, visit
www.CompanyName.co.uk
GPSR ID: 9781906915926-4"

The "9781906915926" is the ISBN and the "-4" indicates that this is the
fourth reprint. Why? Because the printer may be different each time and
hence the materials used may differ as well.

Although this example applies to books, the principle would be the same for
any product, except something requiring specific operating/safety
instructions. It would be wise to put those on the website (maybe linked
via a QR code) so that they can be translated using universally available
online tools.

It's clearly impractical for anyone selling hundreds or thousands of items
into the EU to custom-translate all the relevant info. Multiply 5 minutes
by even 5,000 items then your're looking at 60 working days' worth of work;
no MSME can sustain that level of unproductive admin. So, depending on the
type of item, you'll either have to produce one of those intensely
irritating sheets with the information translated into every conceivable
language - rather pointless in safety terms, because no one can be bothered
to read them - or, better, placed online. When the customer selects
''Language' on the webpage, everything will be in the correct language for
them.

[trafton.-47]

I reckon it's unlikely if you're selling low-risk items out of a low-risk
country.

Printers are amazed that we are even spending time, effort and money on
GPSR compliance - none of their other clients has bothered to get an AR or
to comply in any other way. None, so far as anyone is aware, has had the
slightest problem selling books and related items into the EU.

If you're selling a Cambodian-made children's toy containing explosives*,
then you'll probably run into some issues!

(* I write that in jest in 2025, but when I was a child I had a chemistry
set that did indeed contain acids and explosives!)

[billythecardy]

I was told that the info had to actually be with the product when exported
and that linking to your website wasn't acceptable. It is possible that
this is not correct however as there was so much information and
mis-information flying around when this was implemented.

My EUAR has directed me to include the info in the parcel so that's what
I'm doing. Actually they suggested I put a sticker on the
book/comic/whatever - I'll not be doing that! I have no doubt that
these things will all change as the EU actually deals with stuff.

You're right, selling low-risk items from a low-risk country it seems
unlikely I will suffer the wrath of the EU as I am trying to comply as best
I can. I am just a small business and my EU trade was already decimated by
leaving the EU. Just trying this for a year to see if it's worthwhile -
more for NI really as they're quite a big market for me both on ebay and my
own (unrelated) website.

I think I had one of those chemistry sets too!

[jonatjonatjonat]

You are correct on the info being included on the product/packaging.

Obligations of Manufacturers...
Manufacturers shall indicate their name, their registered trade name or registered trade mark, their postal and electronic address and, where different, the postal or electronic address of the single contact point at which they can be contacted. That information shall be placed on the product or, where that is not possible, on its packaging or in a document accompanying the product.

Obligations of Importers
Importers shall indicate their name, their registered trade name or registered trade mark, their postal and electronic address and, where different, the postal or electronic address of the single contact point at which they can be contacted. That information shall be placed on the product or, where that is not possible, on its packaging or in a document accompanying the product. Importers shall ensure that any additional label does not obscure any information required by Union law on the label provided by the manufacturer.

Obligations of economic operators
The name, registered trade name or registered trade mark, and contact details, including the postal and electronic address, of the economic operator referred to in paragraph 1 shall be indicated on the product or on its packaging, the parcel or an accompanying document.

How many products are actually carrying out those obligations is very much up for debate.