What is an internal compliance system under the GPSR?

A compliance system is part of the manufacturer role

An internal compliance system under the GPSR is the collection of procedures a manufacturer must have in-house to monitor product safety: a complaints register, a way to investigate incident reports, and an approach for when a product turns out to pose a risk after all. It is not a standalone form but an ongoing system — it must be in place as long as the product is on the market, not only on the day of launch.

This obligation rests with the manufacturer, and that is a broader group than most business owners think. Anyone selling a product under their own name or brand is themselves considered a manufacturer under the GPSR — including a web shop that merely has a logo applied to a purchased product, and also anyone who has a product substantially modified. For this group the internal compliance system applies just as much as for a party that manufactures itself. A distributor — anyone reselling a product without their own brand and without modifying it — does not need to set up this system themselves; that obligation lies with the manufacturer, the importer or the authorized representative further down the chain. Anyone in doubt about their own role would do well to establish it first, because the role determines whether this obligation applies.

Where this follows from: Article 9 of the GPSR

Article 9 of Regulation (EU) 2023/988 obliges manufacturers to have internal procedures for product safety, including keeping records of complaints, investigating incident reports and taking action on non-compliant or dangerous products. The regulation has applied directly and identically in all twenty-seven member states since 13 December 2024, so this obligation itself is the same throughout the EU. What does differ is the supervisory authority a manufacturer deals with: in the Netherlands the NVWA, in Belgium the Economic Inspection of the SPF Economy, and in Germany the market surveillance authorities of the federal states with BAuA as the coordinating point.