If you sell exclusively to other businesses, the first question is not who your customer is, but what type of product you sell. The GPSR (Regulation (EU) 2023/988) applies to products intended for consumers, or where it is reasonably foreseeable that consumers will use them. A purely commercial sales relationship does not automatically rule out that second possibility.
The consequence: pure B2B sales of a product that by its nature and use genuinely belongs only in a professional environment typically fall outside the scope of the GPSR. If, on the other hand, you sell products that reach consumers too, or even primarily so — even if the invoice goes to a business — the regulation may well be relevant. The distinction lies in the product and its foreseeable use, not in the status of your buyer.
Why the business invoice address is not decisive
The regulation looks at the end use that is reasonably foreseeable, not at the legal status of the party that pays. A supplier of household appliances that sells only to wholesalers ultimately supplies products that end up in homes. An installation company that purchases components from a wholesaler and then installs them at private residences is, at that point in the chain, engaged in consumer use, even if its own purchasing relationship is commercial.
Conversely: tools, machine parts or raw materials that by their nature, design and market are intended solely for professional use and are also offered as such typically fall outside the scope of application. Supervisory authorities and the regulation itself allow room for assessment on a product-by-product basis; there is no ready-made list of what counts and what does not.
When it does affect your business
There are a few situations in which B2B businesses in practice nevertheless have to deal with it. A wholesaler that, alongside professional customers, also operates a webshop for private individuals has to deal with the regulation for that part of the range. An installation company that places products under its own name or brand at end-users can be considered a manufacturer in doing so, even if its own purchasing is entirely B2B — that is another borderline case that causes more confusion than people expect.
Also, an importer that sources products from a third country and resells them to European businesses that in turn offer them to consumers is somewhere in a chain where the regulation definitely applies, even if its own sales are commercial. The question then is not whether the regulation applies, but what role you fulfil in it and what obligations come with that.
When it does not affect your business
Enterprises that supply solely products that by destination and design genuinely do not reach consumers — think of specific industrial components, building materials that are only processed via certified professionals, or machine parts with a clearly professional application — typically fall outside the GPSR. For that kind of products, other, sector-specific rules often apply, which do not run via this regulation.
So it is quite possible that your business has nothing to do with the GPSR at all, simply because the range does not fall within its scope. That is not an exception to look for, but an outcome that follows from the nature of the product itself.
Borderline cases: mixed range
Many businesses are somewhere in the middle: part of the range is unmistakably professional, another part is also purchased or used by consumers. In those cases, it pays to look at each product line, rather than passing one judgment over the entire business. A webshop can fall outside the regulation for one product and be right in the middle of it for another, with the corresponding role as manufacturer, importer or distributor.
To make that clear, it helps to look not only at whether the GPSR applies, but also at which role is involved. These two questions are closely linked: the role determines which concrete obligations follow, and not every role entails the same burdens. In the knowledge base with worked examples per sector you will find more examples of mixed assortments and how they are assessed.
How you assess this for your own assortment
The most practical approach is to split your assortment by product category and assess for each category whether consumer use can reasonably be expected. This is followed by the question of which role you fulfil for each product category — manufacturer, importer, distributor or pure reseller — because that role determines what is required of you. This distinction is precisely where many businesses get stuck, because role and scope are two separate questions that are often confused.
If you want to get clarity on your own situation, you can do so with a few questions: in five questions see where you stand gives an immediate indication of whether, and if so in which role, the regulation is relevant for your products. If you are still uncertain about the structure of the system behind it, you can read on how the information on this site is organised where the answers come from.
For a definitive assessment of your specific assortment and sales structure, legal advice or consultation with the competent supervisory authority remains the appropriate course; this page describes the methodology, not your individual situation.
If you are still not entirely clear after this article, take the free role check or browse through the most frequently asked questions about the GPSR — both are free and require no account, and both provide a direct, concrete answer.