What are the obligations of a distributor under the GPSR?

A distributor checks, does not create documentation themselves

A distributor under the GPSR is the party that places a product on the market without being a manufacturer, importer, or authorised representative — typically the wholesaler, retailer, or online shop that purchases from a supplier within the EU. Their obligation is supervisory in nature: to verify that the product bears the required marking, that instructions for use and warnings are present and in the correct language, and that the contact details of the manufacturer or importer are found on the product or packaging. Once a distributor knows or has reason to believe that a product does not meet the requirements, they must not offer it and must inform the manufacturer or importer and the supervisory authority. In the case of a dangerous product, they cooperate in corrective measures, such as a recall, and ensure that storage and transport do not compromise the product's safety.

What a distributor need not do: they do not prepare a risk assessment or technical documentation, and the six-year retention obligation does not apply to them either — that is the work of the manufacturer and importer. Important is the boundary at which a distributor ceases to be a distributor: whoever sells a product under their own name or brand is regarded as a manufacturer, even if only a logo has been added or the product has been substantially modified. Whoever supplies in the Netherlands, Germany, and Belgium must also verify that warnings are in the correct language — Dutch, German, or Dutch/French/German depending on the language region in Belgium — because this requirement also applies to the distributor, not only to the manufacturer.

Where this is stated: Article 12 of the regulation

These obligations follow from Article 12 of Regulation (EU) 2023/988, which specifically governs the role of distributor and delimits it from that of manufacturer and importer elsewhere in the same regulation.