Product Safety When Importing: CE, GS, GPSR & Liability

Anyone importing goods from the Far East into Germany takes on more than just the purchase: with the import, you legally become the party placing the product on the market and carry responsibility for product safety. This applies to a technical component as much as to a consumer product, from tools and toys to equipment for booming trend sports. This is exactly where many importers underestimate what they are taking on, because the foreign manufacturer is generally not liable in the EU market.

In brief: When importing from the Far East, product responsibility lies with the importer, not the manufacturer. Depending on the product, CE marking is mandatory, applicable EN standards must be met, and since late 2024 the requirements of the EU General Product Safety Regulation (GPSR) apply. The voluntary GS mark builds additional trust. Product safety can be secured through a precise specification, complete technical documentation and a quality inspection before shipping.

Who is liable for product safety when importing from the Far East?

EU law is clear: whoever first makes a product available on the European market is the party placing it on the market and is liable for its safety and conformity. If the manufacturer is based outside the EU, the importer steps into this role. They must ensure the product meets the applicable product safety requirements, hold the necessary documentation, and answer for it in the event of a claim.

This has tangible consequences. If market surveillance finds defects, the result can be a sales ban, recall and fines, and in a liability case, damages too. A batch ordered without clarified product safety may, in the worst case, be unsellable: the capital is tied up, the goods unusable. Product safety is therefore not a downstream formality but belongs at the start of every sourcing project.

Anyone who checks product safety only after placing the order is merely shifting the risk, not reducing it. Product safety questions belong in every specification sheet and every supplier conversation, not in the complaint that follows later.

In our sourcing projects in the Far East, we regularly see importers only check product safety requirements once the goods have already shipped. By that point, missing test reports or incomplete technical documentation can barely be obtained retroactively without delaying the shipment or having the entire batch re-produced.

The European GPSR is complemented at national level by the German Product Safety Act (ProdSG). As an EU regulation, the GPSR applies directly without national transposition; the ProdSG instead governs market surveillance, sanctions and the authorities' responsibilities in Germany. For importers, a breach of the GPSR also triggers consequences under the ProdSG in the German market.

Who carries which duty can be mapped to four key roles in the supply chain:

When is CE marking mandatory when importing?

CE marking is the best-known but also the most frequently misunderstood product safety requirement. It is not a quality seal or an award, but the declaration by the party placing the product on the market that it meets the applicable EU directives. Many product groups, from electrical devices and machinery to personal protective equipment, fall under a CE marking obligation.

Importantly, responsibility for correct CE marking lies with the importer. It is not enough to rely on the supplier's statement that "the product is CE". The importer must be able to substantiate the underlying conformity and hold the EU declaration of conformity and the technical documentation. Without this product safety evidence, the product may not be placed on the market. A good overview of use cases and obligations is provided by the official EU information on CE marking.

A first orientation on where the CE obligation typically applies:

What do the GS mark and EN standards add beyond CE marking?

Unlike the CE mark, the GS mark ("tested safety") is voluntary. It is awarded by an independent testing body approved by bodies such as Germany's Zentralstelle der Länder für Sicherheitstechnik (ZLS) and confirms that a type sample has been tested. In the German market the GS mark enjoys high trust and is an argument for many trade partners that goes beyond the baseline product safety obligation.

Closely related are the EN standards, harmonised European standards developed by the bodies CEN and CENELEC and published nationally through institutes such as DIN. They define concrete test requirements for many product classes, for example on stability, load capacity or freedom from harmful substances. Anyone who has a product developed and tested to the applicable standard creates the basis for the declaration of conformity. These standards belong in the specification long before the first order is placed. For importers who take product safety seriously, combining EN standards with the GS mark is often the standard that demanding trade partners expect anyway.

The three instruments operate on different levels and are frequently confused in practice. The overview below places them side by side:

What does the GPSR change for importers since late 2024?

Since December 2024, the EU General Product Safety Regulation (GPSR) has applied and tightens the requirements for almost all consumer products not already covered by sector-specific rules. Three points of the regulation are particularly relevant for importers from the Far East:

• Traceability: products must be clearly identifiable, and a responsible economic operator in the EU must be named.

• Risk analysis and technical documentation: an assessment of risks must be documented for each product.

• Information and reporting obligations: in the event of safety problems, there are reporting and recall obligations towards authorities and consumers.

The European Commission provides an overview of the GPSR that breaks down the obligations by economic operator. Anyone importing from the Far East should clarify GPSR conformity with the manufacturer early, because missing traceability or incomplete documentation can block market access.

How do you secure the conformity of your shipments?

Knowing standards and regulations is one thing; ensuring compliance across the distance is another. Three levers are decisive if product safety is not to be left to chance.

First, the specification. All relevant standards, limits and marking requirements belong in the spec sheet before production. A supplier can only fulfil what is clearly defined.

Second, inspection before shipping. A sampling inspection to Acceptable Quality Level (AQL) uncovers deviations while the goods are still at the factory. A complementary incoming goods inspection secures the delivery after arrival. Anyone qualifying a new supplier should first conduct a supplier audit to assess production and inspection competence.

Third, documentation. The declaration of conformity, test reports and technical files must be complete and kept for years. In a dispute or inspection, product safety documentation is what counts.

Anyone who applies these three levers consistently makes product safety a fixed part of the sourcing process rather than a correction made after the fact.

From our experience with suppliers in China, a fourth lever is worth adding: sign off the inspection plan before the sample production run. Fixing test method, sample size and acceptance criteria in writing beforehand cuts the risk of conflicting interpretations between buyer and factory.

How the goods then reach Germany in a legally compliant way is described in our guide on importing from China; which delivery terms apply is clarified in the article on Incoterms.

What does product safety mean for a trend product like padel equipment?

A current example makes this tangible. With the boom in sports such as padel and functional training, many retailers and founders want to offer their own equipment. A piece of sports equipment is mechanically stressed in use and has to protect people, so product safety is immediately felt here: applicable EN safety standards, robust material testing and GPSR-compliant documentation decide whether the product may be sold. Anyone planning an own brand will find the strategic side in the guide to building your own padel brand. The principle applies to every imported product: product safety first, then the sale.

Frequently asked questions about product safety when importing

Who is liable for the safety of imported products? In the EU market, the party placing them on the market. When importing from a third country, this is usually the importer, not the foreign manufacturer. They must ensure product safety, hold documentation and answer for it in a claim.

Is CE marking mandatory for all products? No. The CE obligation applies to product groups that fall under certain EU directives, such as electrical devices, machinery or protective equipment. Other products are covered by other or general rules such as the GPSR. The correct classification before import is decisive.

What changes with the GPSR? Since the end of 2024, the EU General Product Safety Regulation has tightened requirements on traceability, risk documentation and reporting for almost all consumer products. Importers need a named responsible economic operator in the EU and complete technical files.

How do I ensure my supplier in the Far East produces compliant goods? Through a standards-compliant specification, sample approval, a quality inspection before shipping to a standard such as AQL, and complete documentation. A partner with their own office on the ground can carry out product safety inspections directly at the factory.

What does poor product safety cost in the worst case? Beyond a sales ban and recall, importers risk damages claims, reputational harm and the loss of trade partners. Investing in product safety before the order is placed is consistently cheaper than correcting it afterwards.

Conclusion: product safety decides the market success of imported goods

Product safety is not a bureaucratic add-on but the precondition for imported goods to be sellable at all, and the best protection against expensive recalls and liability cases. The key is to clarify CE marking, the GS mark, EN standards and the General Product Safety Regulation not at the end but at the beginning of sourcing.

At Line Up, with over 30 years of experience in global procurement and our own office in the Far East, we support you in doing exactly that: from a standards-compliant specification through supplier qualification and on-site quality control to complete product safety documentation. This way your goods arrive not only at a good price but also compliant and ready to sell.

👉 Are you planning an import and want to secure product safety from the start? Get in touch for a no-obligation consultation.