GPSR for Clothing Brands: The Responsible Person, the Technical File and What Your Factory Must Supply
The General Product Safety Regulation (EU) 2023/988 has applied to clothing sold in the EU since 13 December 2024. For a brand importing garments it means three things: an EU-established economic operator responsible for the product, the manufacturer's name and addresses on the garment or packaging, and a technical file with a risk analysis kept for ten years. Your factory supplies the file's substance; you hold it.
Who is the responsible economic operator?
Article 16 of the Regulation requires, for every consumer product placed on the EU market, a responsible economic operator established in the EU: the manufacturer if it is in the EU, otherwise the importer, an authorised representative appointed in writing by the manufacturer, or a fulfilment service provider. A factory in Bangladesh cannot be that operator. If your company is in the EU, it is you as importer. If your brand is outside the EU and you sell into it, you appoint an EU authorised representative or work through an EU importer. The operator's name and contact details must be traceable to the product, and the operator is who market-surveillance authorities contact.
What has to be on the garment?
The manufacturer's name, registered trade name or trade mark, and its postal and electronic address, on the product or, where that is not possible, on the packaging or an accompanying document, along with a type, batch or serial number that identifies the product. On a garment that usually means a second label or a printed care-label panel. It sits alongside the fibre-composition label required by Regulation (EU) No 1007/2011, in the language of the member state of sale; our labelling guide covers that side.
What goes in the technical file?
The Regulation requires the manufacturer to carry out an internal risk analysis and to draw up technical documentation describing the product and its safety-relevant characteristics, kept for ten years after the product is placed on the market and made available to authorities on request. For a garment the file that authorities and retailers actually ask for holds:
- Identification: style, batch, the responsible operator and the factory that made it.
- Materials: fibre composition of every fabric and trim, from the mill's specification, not the label.
- Chemical compliance: evidence that dyes and finishes meet REACH, in particular Annex XVII entry 43, which bans azo dyes that can release listed aromatic amines above 30 mg/kg in textiles worn against the skin; test reports or a certified chain of custody cover this.
- Physical safety: for children's clothing, conformity with EN 14682 on cords and drawstrings; for anything with small parts or trims, the pull-test results.
- Traceability: which order, which fabric lot, which line, so a problem can be traced to a batch rather than a brand.
- The risk analysis itself: a short, honest document listing the hazards considered (strangulation, choking, chemical, flammability) and why the product is safe against each.
What should you ask your factory for?
The file is your obligation, but its substance is the factory's records, and a factory that cannot produce them leaves you unable to comply. Ask for four things before you place an order: the mill specification for every fabric; chemical test reports or a certification that restricts inputs; the construction and trim details for children's styles measured against EN 14682; and lot-level traceability from fabric to carton. We build that file during production and hand it over with the shipment. GOTS certificate RSC 9687 does most of the chemical and traceability work for organic styles, because the standard restricts inputs and audits chain of custody; the GOTS page explains what it does and does not cover, and it is worth being clear that GOTS does not replace the GPSR file, it feeds it.
Does GPSR apply to the UK too?
Not as such. Great Britain kept the General Product Safety Regulations 2005 after leaving the EU, and Northern Ireland follows the EU regulation under the Windsor Framework. The practical requirements overlap heavily, from the safety duty to the designated standard BS EN 14682 for children's cords, but the responsible-person mechanism is the EU's. If you sell into both, one technical file serves both, and our UK page covers the GB-specific labelling rules.
What is coming next: the Digital Product Passport
Separately from GPSR, the Ecodesign for Sustainable Products Regulation will require a Digital Product Passport for apparel. The Commission's plan is a textile delegated act adopted in late 2027 with a transition of at least 18 months, so the passport is not a 2026 obligation, but the data it will carry, fibre composition, care, origin and operator identity, is the same data a GPSR file holds today. A brand that builds the file properly now is most of the way there; our DPP guide has the timeline.
A short compliance checklist
| Item | Who does it | When |
|---|---|---|
| Appoint or confirm the EU responsible economic operator | You | Before the first EU sale |
| Manufacturer name, trade mark, postal and electronic address on the garment or packaging | You supply, factory prints and sews | Before label artwork is approved |
| Fibre composition in the member state's language | Factory supplies data, you approve the label | Before production |
| Chemical evidence (REACH Annex XVII; GOTS chain of custody for organic) | Factory | With the shipment |
| EN 14682 check on children's styles | Factory designs, you confirm | At sampling |
| Risk analysis and technical file, kept 10 years | You, from the factory's records | Before the product is placed on the market |
| Accident and recall reporting via the Safety Business Gateway | Responsible operator | If it ever happens |
Frequently asked questions
I am a small brand outside the EU selling online to EU customers. Does GPSR apply to me?
Yes. The Regulation applies to products placed on the EU market by any route, including distance selling, and it requires a responsible economic operator established in the EU for each product. If you have no EU company you appoint an authorised representative in the EU in writing, or sell through an EU importer or fulfilment service provider that takes on the role. Marketplaces also check for it. Our Amsterdam office can sit as the EU-established point where that suits your structure, but the obligation is yours as the brand.
Does GOTS certification satisfy GPSR?
No, and the distinction matters. GPSR is a legal obligation on the economic operator: a responsible person in the EU, product marking, a risk analysis and a technical file kept for ten years. GOTS is a voluntary textile standard that restricts chemical inputs and audits the chain of custody. What GOTS does is supply much of the technical file's substance for organic styles, because the fibre origin, restricted inputs and chain-of-custody records already exist. The file still has to be assembled and held by you.
What has to be printed on the garment under GPSR?
The manufacturer's name, registered trade name or trade mark, postal address and electronic address, plus an identifier such as a batch or style number, on the product itself or, where that is not possible, on its packaging or an accompanying document. For clothing that is typically a second sewn-in label or a panel on the care label. It sits alongside the fibre-composition label required separately by Regulation 1007/2011.
How long do I have to keep the technical documentation?
Ten years after the product is placed on the market, and it must be available to market-surveillance authorities on request. The practical consequence is that the file has to be built during production, when the fabric lots, test reports and construction details exist, not reconstructed years later when a question arrives. We assemble it as we go and hand it over with the shipment.
Is EN 14682 a legal requirement?
It is the European standard for cords and drawstrings on children's clothing, and conformity with it gives a presumption that the garment meets the general safety requirement on that hazard; in the UK it is a designated standard under the 2005 regulations. Designing to it is the sensible way to show the drawstring risk was managed. For garments intended for young children it means no cords in the head, neck or upper-chest area at all; for older children it limits free ends. We design children's styles to it from the first sample.
Where this applies
The manufacturing pages this guide relates to, if you are costing a real run.
Free tools & guides for this
Sources & further reading
- EUR-Lex — Regulation (EU) 2023/988, General Product Safety Regulation
- EUR-Lex — summary of the General Product Safety Regulation
- EUR-Lex — Regulation (EU) No 1007/2011 on textile fibre names and labelling
- ECHA — REACH Annex XVII entry 43, azocolourants and azodyes
- GOV.UK — PRISM risk assessment: cords and drawstrings on children's clothing (BS EN 14682)
- European Commission — Digital Product Passport for textiles and apparel
Have an idea? Let’s make it.
We manufacture from 100 pieces per style, with GOTS-certified organic options and photos at every stage. Send a sketch or a sentence — we’ll reply within a day.
