Two EU rules now decide whether your pet products
stay on sale, and neither of them can be satisfied by the factory that makes them. One requires a person
physically established in the EU. The other requires a packaging registration in every country you sell
into. Both are enforced by the marketplaces before your listing ever goes live.
The short answer
If you sell pet products into the EU, you need two things in place
before you can list: an EU-established Responsible Person whose details appear on the
product and in the listing (GPSR, in force since 13 December 2024), and a packaging EPR
registration in each member state you first place goods on the market (PPWR, in force since
12 August 2026). Your supplier cannot do either of these for you — but a supplier who cannot give you
the underlying data will stall you at the point of listing.
What changed, and when
Both rules were published years before they applied, which is why so many sellers are meeting them at the
point of enforcement rather than at the point of planning.
| Rule | Legal reference | In force | What it obliges you to do |
|---|---|---|---|
| GPSR | Regulation (EU) 2023/988 | 13 December 2024 | Designate an economic operator established in the EU as the Responsible Person; put their name, postal address and email on the product, the packaging or an accompanying document — and in the online listing. |
| PPWR | Regulation (EU) 2025/40 | 12 August 2026 | Register for packaging EPR in every member state where you first place packaged goods on the market. No single EU-wide number exists: Germany (LUCID), France (IDU) and the rest are separate. |
| France packaging representative | National EPR scheme | 10 July 2026 | Sellers not established in France must appoint a French representative for packaging EPR. |
| Digital labelling | PPWR | 2027 | QR codes carrying structured environmental data, alongside the physical label. |
| Recycled content and grading | PPWR | 2030 | Recycled-content thresholds for plastic packaging and recyclability grading. |
Rule one: GPSR — a real person inside the EU
The General Product Safety Regulation replaced the older directive and applies to almost every non-food
consumer product sold into the EU, online or offline. Its reach is deliberately territorial in the opposite
way to what most sellers expect: it follows the customer’s location, not yours. Selling from
China, the US or the UK to a customer in the EU puts you inside its scope.
Article 16 is the operational part. A product cannot be placed on the market unless an economic operator
established in the EU is designated as the Responsible Person — an EU manufacturer, an importer, an
authorised representative, or in some cases a fulfilment service provider. That person’s name, registered
trade name, postal address and email must appear on the product, the packaging or an accompanying document,
and in the online listing (Article 19).
The Responsible Person is not a mailbox. They must hold the technical documentation for ten years, respond
to market surveillance authorities, cooperate on corrective action and report incidents. Enforcement through
2025 and 2026 has started checking whether the appointed entity can actually produce the technical file and
answer within the required window — which is why “shell” representative arrangements are now a named failure
mode rather than a grey area.
Rule two: PPWR — one registration per country, checked before you can list
The Packaging and Packaging Waste Regulation came into force across all 27 member states on 12 August 2026
as a directly binding regulation. Because it is a regulation rather than a directive, there is no national
transposition process to wait for — but compliance is still administered country by country, and that is the
part that catches sellers out.
- EPR registration is per member state. Germany’s LUCID and France’s IDU are separate
registrations, and there is no single EU number that covers them all. Registering in one country does not
cover the next. - Platforms now gate on it. Article 45 requires online marketplaces to collect proof of a
seller’s EPR registration for the consumer’s member state before allowing a sale. In practice the listing
is blocked first and the discussion happens afterwards. - Material limits apply to every layer. The combined concentration of lead, cadmium,
mercury and hexavalent chromium is limited to 100 mg/kg across packaging layers, and there are separate
restrictions on PFAS for food-contact packaging. - The direction of travel is more data, not less. Digital labelling follows in 2027, and
recycled-content thresholds and recyclability grading in 2030.
Do pet products count? Yes — including the ones people assume are exempt
Pet accessories sit squarely inside GPSR: harnesses, leads, collars, beds, mats, carriers, grooming tools
and pet clothing are all consumer products without a more specific EU safety directive to fall back on. That
absence of a fallback is exactly why the general obligations — risk analysis, technical file, batch
traceability, manufacturer information and the Responsible Person — apply in full rather than being
softened.
“It’s for animals” does not exempt a product. What does sit in a different regime is pet food and treats
(feed law), veterinary medicines and biocides. Electrical pet products may additionally fall under
electrical safety and EMC rules, with GPSR as the safety net beneath them.
Who does what: the split sellers get wrong
Neither GPSR nor PPWR asks the factory to register for anything. Both ask the seller — and both require
inputs that only the factory holds. This is the practical line to draw with your supplier.
| Task | Whose obligation | What the supplier must hand over |
|---|---|---|
| EU Responsible Person | Seller (importer or authorised representative) | Manufacturer identification, product model and batch identifiers, and a point of contact the authority can reach. |
| Technical documentation | Seller, held via the Responsible Person for 10 years | Materials and construction, dimensions, care and use information, batch records. |
| Listing information | Seller, in every listing | Product identifiers that match the physical label, so the listing and the carton agree. |
| Packaging EPR | Seller, in each member state | Packaging weight and material by component — the figures the EPR declaration is built from. |
| Packaging material limits | Seller, demonstrated via the supply chain | Declarations covering inks, coatings and the individual packaging layers. |
| Labelling content | Seller designs it; supplier prints it | Label and hangtag artwork applied exactly as supplied — including space for the Responsible Person’s details. |
The six inputs to ask your supplier for
If you are sourcing from outside the EU, these are the items that decide how smoothly the listing and the
registration go. Ask for them in writing, before the order, not after:
- Model and batch identifiers that appear on the physical product and can be repeated in
the listing. - Material composition by component — face fabric, filling, backing, hardware.
- Packaging weight and material, separated — polybag, box, hangtag and carton, because
the EPR declaration is built per material, not per carton. - Declarations for inks, coatings and adhesives, which sit inside the heavy-metal and
PFAS limits. - Care and use information in the languages of your market, for the technical file and
the label. - Confirmation of what is printed where — so the Responsible Person’s details have a
defined place on the pack rather than being squeezed in at the last minute.
Where sellers actually fail
- No Responsible Person at all. The most common case for sellers who started selling
into the EU before 2025 and never updated their listings after 13 December 2024. - A representative who cannot produce documents. Enforcement now tests whether the
appointed entity holds the technical file and responds within the required window. - Registration in one country, sales in five. Registering in Germany and shipping to
France, Italy and Spain leaves four gaps that the marketplace — not the authority — will find first. - Packaging declared by carton rather than by material. The weight was known; the split
between plastic, paper and metal was not, so the declaration cannot be filed without a new round of
questions to the supplier.
Questions we get asked
Is this a supplier’s job or a seller’s job?
The registrations are the seller’s: the Responsible Person under GPSR and the packaging EPR filings under
PPWR are both placed on the economic operator placing the goods on the market. The supplier’s role is to
provide the underlying data — identifiers, materials, packaging weights and declarations — reliably and in
writing.
Can a factory outside the EU act as my Responsible Person?
No. The Responsible Person must be established inside the EU. A non-EU manufacturer can support you with
the technical documentation, but it cannot hold the role itself.
We only sell through a marketplace — does that change anything?
It changes the order of events rather than the obligation. Under PPWR Article 45 the marketplace must
collect proof of your EPR registration before allowing the sale, so a missing registration blocks the
listing rather than waiting for a fine.
Do washable pads and textile pet products need anything beyond the general rules?
They are consumer products without a product-specific EU safety directive, so the general GPSR obligations
apply in full: risk analysis, technical documentation, batch traceability and the Responsible Person. Textile
labelling requirements sit alongside them and depend on your market.
What should I ask you for, specifically?
Ask for the six inputs listed above and we will confirm in writing which ones we can supply for your
model and which we cannot. We do not claim certificates we have not seen, and we will tell you plainly
when a document is your responsibility to arrange rather than ours to issue.
If you are planning a senior-dog range for a European market, tell us the countries
you sell into and the quantity you are considering. We will come back with the pricing, the sample options,
and a written list of the inputs we can supply for the compliance work that sits on your side of the
border.