GPSR (General Product Safety Regulation)

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The General Product Safety Regulation (GPSR) is a key component of the European Union's product safety framework, set to replace the current General Product Safety Directive and the Food Imitating Product Directive on December 13, 2024. This regulation aims to modernize product safety standards, addressing challenges posed by digitalization and online sales. [1]

This article is focused on the requirements that Amazon imposed concerning compliance, at the end of November 2024, with a deadline on December 13, 2024. Additionally, it mostly only covers the stuff that is relevant for a customer of mine, selling certain replacement parts, mostly for powertools.

Introduction

The GPSR applies to all consumer products, including new, used, repaired, and reconditioned items, across all sales channels, parts as well as complete products. It establishes specific obligations for businesses to ensure product safety and serves as a safety net for products or risks not covered by other EU legislation. For businesses operating within the EU, it's crucial to understand and comply with the GPSR to ensure that all consumer products meet the updated safety standards. This regulation aims to provide a high level of consumer protection and create a level playing field for businesses within:

  • Precautionary Principle: Emphasizes the application of precautionary measures by all stakeholders to ensure product safety
  • Obligations for Economic Operators and Online Marketplaces: Introduces specific safety obligations for manufacturers, importers, distributors, and online marketplace providers
  • Enhanced Product Traceability: Implements stricter requirements to trace products throughout the supply chain
  • Safety Assessments for New Technologies: Includes criteria for assessing the safety of products incorporating new technologies
  • Accident Reporting: Mandates businesses to report accidents related to their products to authorities
  • Improved Market Surveillance and Recall Procedures: Strengthens rules for market surveillance and outlines specific procedures for product recalls, including a mandatory recall notice template and consumer rights to remedies.

Context

Technical products

This article is limited to specific technical products for a specific seller/manufacturer. These are usually low-voltage components, but not always - That distinction might be relevant concerning e.g., safety.

CE marking

The GSPR is not the same as the CE marking, neither replaces it:

  • CE marking only applies to products covered by specific EU harmonized directives or regulations, such as those for machinery, medical devices, toys, and electronics and usually only for complete products, not parts - GSPR applies to basically all non-food consumer products, including parts
  • CE marking: Manufacturers must conduct a conformity assessment, create a technical file, and issue an EU Declaration of Conformity before applying the CE mark - GSPR: Mostly administrative and organisational requirements
  • CE marking requires a marking - GSPR doesn't involce a marking or logo.

Only consumer goods

  • The GPSR specifically applies to consumer products—goods intended for or likely to be used by consumers. It does not apply to non-consumer goods, such as industrial equipment or machinery exclusively intended for professional or business use
  • Specifically: It applies to consumer goods that are likely to end up in consumer goods
  • 'Dual-use goods' (products that can reasonably be expected to be used by both consumers and professionals) are covered by GPSR.

This seems similar to the current rules concerning displaying prices on webshops with or without VAT: You are only allowed to display prices without VAT, if you're really sure that no consumers would en up there - Like by requiring a vetted login procedure.

It makes sense that e.g., Amazon, requires GSPR for all its products: AFAIK, there isn't much of a mechanism to keep consumers from buying non-consumer stuff (actually there is - nevermind).

Amazon first

GPSR was first introduced to us because of requirements from Amazon. Hence, their specific requirements are more-or-less leading in this article.

Amazon: Only European marketplaces

Concerning selling on Amazon Marketplaces, I believe that GPSR compliance only applies to European marketplaces. However, I am not completely sure about this, and the cited source [2] isn't that clear to me.

Amazon: Pan-European FBA

We make use of both FBA and FBM. Concerning FBA, all goods are shipped to a French warehouse, from where goods are sold through multiple European Amazon sites - This probably has implications concerning languases used for labeling - See a later chapter for more on this.

Deadline: Dec. 13, 2024

Amazon Marketplaces requires GPSR compliance from Dec. 13 2024 on.

Amazon: Provide proof

Amazon Marketplaces requires proof of GSPR compliance.

Comply to the target public only

I believe that products on webshops and marketplaces like Amazon, only need to comply with the intended public. E.g.:

  • Amazon.fr: Only needed in French, even if a customer is located in another country
  • Amazon.de: Only needed in German + follow specific German rules like concerning impressum
  • example.nl: Only needed in Dutch, etc.

Background

If a webshop is explicitly targeted at a specific jurisdiction, such as the Netherlands, and a consumer from another jurisdiction places an order, the webshop is generally not obligated to comply with the consumer protection laws of the consumer's jurisdiction. This principle is rooted in the European Union's approach to determining jurisdiction in cross-border consumer contracts.

  • Targeting Criterion: The European Court of Justice (ECJ) has established that for a business to be subject to the consumer protection laws of another EU Member State, it must be shown that the business directed its activities toward that state. This was clarified in the Pammer and Alpenhof cases, where the ECJ provided criteria to assess whether a business's activities are directed at a particular Member State
  • Indicators of Targeting: Factors indicating that a business is targeting consumers in another jurisdiction include:
    • Using the language or currency of the consumer's country
    • Providing delivery options to that country
    • Purchasing online advertising aimed at consumers in that country.

Source (related to background): https://en.wikipedia.org/wiki/Pammer_and_Alpenhof_cases

Or not?

However, when I am mistaken, it would mean that when fulfilling an order on Amazon.de to a customer in Switzerland, that required texts must be in French, German and Italian [3], etc.

Made in...

In the EU, there is no general obligation to include a "Made in..." statement on labels, with specific exceptions:

  • Food
  • Textiles
  • Medical devices
  • Goods governed by some specific electrical safey regulations.

However, this may be obligatory when exporting, e.g., to USA or Canada - Again, through channels intented for those territories.

Requirements - Brainstorm

Every kind of document or requirement I came across, is included here - At least, that's the intention. If something is not somehow mentioned here, there is something wrong.

Product information requirements according to GPSR, related rules and Amazon
Requirement Source Notes
CE marking General Not GPSR-related, not relevant for parts
Packaging labeling General France, Italy, Spain, UK and possibly other countries, have various requirements. E.g., obligatory Triman logo in France[4]
Existing labelling & traceability requirements Amz Meet existing labelling and traceability requirements

Amazon [5]: verify the compliance of your products with existing legislation. Your products must satisfy all existing requirements, and the corresponding documents (such as the technical documentation and test reports, and a declaration of conformity) must be drawn up

RP General Have an EU Responsible Person (RP) for those products
RP contact information labeling Amz Label the products with the contact information of the RP
Provide RP with copies of the applicable existing requirment documents (declaration of conformity, technical documentation, etc.) Amz
Manufacturer contact information Amz Label the products with the contact information of the manufacturer
Importer contact information Amz Label the products with the contact information of the importer (if applicable)
Product identifier Amz Products must carry a product identifier. This is the same requirement as ...type, batch, or serial number... . Examples:
  • EAN
  • On Amazon: FNSKU - not ASIN
Traceability Amz It seems that a proper product identifier, is good enough concerning traceability.
GPSR Safety Attestation? (yes/no) Amazon product edit page
  • "Does this product require any warning or safety information? Or can it be used safely as intended without it?"
  • If the answer is "no", most of the stuff concerning GPSR is nicely not relevant for you
Safety information labeling --- Label products with safety information and warnings, where applicable, in the language of the country of sale
Amazon Compliance Media Amazon listings Product Edit » Compliance Media » Compliance Media Content Type. See a screenshot somewhere around here. Some of these Compliance Documents are mentioned separately here below
Application guide
Applicatiegids
Amazon Compliance Media Not relevant
Certificate of Analysis
Analysecertificaat
Amazon Compliance Media Not relevant
Certificate of Compliance
Certificaat van conformiteit
Amazon Compliance Media Not relevant
Compatibility Guide
Compatibiliteitsgids
Amazon Compliance Media Not relevant
Emergency use authorization
Autorisatie gebruik noodgevallen
Amazon Compliance Media Not relevant
Emergency use authorization amendment
Amendement autorisatie noodgebruik
Amazon Compliance Media Not relevant
Installation manual
Installatiehandleiding
Amazon Compliance Media Relevant (3/4)
Instructions for use
Gebruiksaanwijzing
Amazon Compliance Media Relevant (2/4)
Patient fact sheet
Informatieblad voor patiënten
Amazon Compliance Media Not relevant
Provider fact sheet Amazon Compliance Media
Informatieblad provider
Not relevant
Safety data sheet
Veiligheidsinformatieblad
Amazon Compliance Media Not relevant
Safety information
Veiligheidsinformatie
Amazon Compliance Media Relevant (1/4) - Probably the most important Amazon compliance media, compliance document or ComDoc
Specification sheet
Specificatieblad
Amazon Compliance Media Not relevant
Troubleshooting guide
Handleiding probleemoplossing
Amazon Compliance Media Not relevant
User guide
Gebruikersgids
Amazon Compliance Media Relevant (4/4)
User manual
Gebruikershandleiding
Amazon Compliance Media Not relevant
Warranty
Garantie
Amazon Compliance Media Not relevant
Chocking hazard warning General Might be obligatory, as products are delivered by post
RP contact details Amz listings Amazon online listings: The Responsible Person information and the manufacturer’s name and contact details for each product - in the product detail page
Product photo Amz listings Amazon online listings: A product picture, needed to identify the product
Warning & safety information photo(s) Amz listings
  • "Upload up to six images of the product, or packaging, that show warning and safety information required for the product by using the product safety PS01-06 image variants"
  • Source: Amz Seller Central » Product Policy Compliance » Reason » Warning and safety images
  • You don't need to blindly upload package photos. E.g., if all the information is printed on the product, than that should be uploaded
  • See screenshot somewhere around here
Additional product identification information Amz listings Amazon online listings: Any other information, needed to identify the product
Warning & safety informationYou probably can include multiple Compliance documents: Just click on Amz listings Amazon online listings: Warning and safety information, in the language of the country of sale.
Editing an article » Amazon Compliance Documents: here on Amz.nl, there are appearantly 17 such documents. None of which apply all the time. They are displayed in the language of the intended public, not the language of the account. Hence here on Amz.nl, they are titled in Dutch
This is the reason for uploading product packages. Location: Seller Central » Performance » Account Health » Regulatory compliance » <choose a product> » "Reason" » Warning and safety images (if this applies)
Amazon product edit page: You probably can include multiple Compliance documents: Just click on Add More
Amazon product edit page: Compliance documents » Add More: Now you can add an additional document
Product information that is not required according to GPSR or similar guidelines
Requirement Notes
Product name No requirement to include a specific, exact product name
Made in... For products intended for the EU, this it not required

Manufacturer contact information

The labeling with the manufacturer information must be placed on the product, and only if that isn’t possible can you place it on the packaging or in a document accompanying the product. If you’re using a QR code, you must also print the information in text form.

Product picture (Amazon)

This is concerning Amazon marketplaces [6]:

You must also display a product picture to identify the product on the product detail page. If there is already a main image of the product on the detail page, you are compliant with this requirement. If not, you must upload a main image in the Image Manager.

Product identifier (Amazon)

[7]:

you must physically label those products with at least one product identifier, such as the type, batch, or serial number, or another element to make it possible for a customer to identify the product. You must ensure that the information is easily visible and legible for consumers. You may be able to use the Fulfillment Network Stock Keeping Unit (FNSKU) for your product, but there are other, more recognizable identifiers, such as European Article Number (EAN), Global Trade Item Number (GTIN), or manufacturer part number.

Alternatives to individual identifiers

For small or technical products like bolts, nuts, and other components where including a physical product identifier (e.g., batch or LOT number) on the item itself is impractical, regulations like the GPSR provide flexibility:

  • Package-level identification. Example: A bag or box of bolts would carry the necessary product identifier, even if individual bolts do not.
  • Accompanying Documentation: Traceability details can be included in accompanying documents, such as delivery notes, product manuals, data sheets or warranty cards. Example: A shipment of industrial fasteners may come with a label or a certificate that includes batch numbers and manufacturer details
  • Digital traceability: Use QR codes, RFID tags, or barcodes on the packaging or associated documentation to store traceability data
  • Industry-specific standards: For technical parts, standards like ISO 9001 (quality management) may provide additional guidance on traceability for small items.

Traceability without individual identifiers

The manufacturer must ensure that traceability is achieved through other means if individual marking isn’t feasible.

  • Distributors and importers must retain documentation and ensure that products in their supply chain are linked to the required identifiers.
  • Traceability for technical parts rarely involves direct consumer use; it is primarily for business-to-business (B2B) and safety or recall purposes.

Example: Bolts and Nuts:

  • Product Packaging: A bag of 100 bolts includes a label with the batch number and manufacturer details
  • Supply Chain Documentation: The invoice or delivery note includes traceability information (e.g., supplier name, LOT number)
  • Digital Link: A QR code on the packaging links to a database with detailed product specifications, manufacturing dates, and batch records.

Responsible Person (RP)

Economic Operator

The GPRS outlines the requirements for a "responsible person" in Article 16. This article specifies that products cannot be placed on the EU market unless there is an economic operator established within the Union responsible for certain tasks. The term "economic operator" encompasses entities such as manufacturers, importers, authorized representatives, and fulfillment service providers.

The GPSR does not explicitly state that the responsible person must be an individual. Instead, it refers to "economic operators," which can be either natural persons (individuals) or legal persons (entities like companies).

Contact information

Required contact information concerning the RP (GPSR - Article 16):

  • Full name - If the RP is a natural person
  • Registered trade name or trademark - The official name under which the RP operates
  • Postal address
  • Electronic address (email or something similar, e.g., a webform)

Where to find an RP?

RPs are usually found here (always within the EU):

  • The manufacturer or brand
  • The importer
  • An authorised representative - Can be an outside person, similar to GDPR contact persons can be outside persons

Labeling

The labeling with the Responsible Person or importer information can be attached to the product, its packaging, the parcel, or an accompanying document [8].

Identification & traceability

E.g.:

  • EAN
  • For Amazon: FNSKU

One EAN, different sources

When product parts are sources from various OEM suppliers, this probably needs to be accounted for concerning traceability. One way to do so:

  • Products have an SKU, in addition to an EAN - Include this SKU in the product information
  • Have a suffix to the SKU, to identify the sourcing. However, a problem with this might be, that an additional action is needed during fulfillment.

Choking hazard warning

It's not clear to me if we need to include a choking hazard warning for these technical products:

  • These products are not intended for children
  • On the other hand: They get delivered by post and that might require this.

Including the usual symbol for this, is only needed when the goods are (parts of) toys, or could be confused for toys.

White labeling

How about the situation that OEM products are resold under a VAR's name with a VAR's EAN?

No problem. Under EU law, this effectively makes you the manufacturer of the products. This has quite some implications concerning GPSR and other directives

  • Specifically: You are responsible for ensuring safety and compliance of the product
  • GPSR
  • CE Marking Directives (if relevant)

Maintanance of technical documentation:

  • Safety assessments
  • User instructions and warnings
  • Traceability records.

Consumer rights and liability:

  • You are liable for any defects or safety issues with the product
  • Be prepared to manage recalls, complaints, or legal challenges if a product fails to meet safety or quality standards.

OEM agreement

Have an agreement with the OEM:

  • That the OEM agrees with white-labeling
  • Compliance concerning EU standards
  • Certificates of conformity.

VAR label over OEM label

You can affix your label over the OEM (Original Equipment Manufacturer) label when white labeling:

  • If the OEM label contains information like another company's name or non-compliant details, covering it with your label is acceptable and often necessary to avoid confusion
  • The OEM's name or brand should not be visible if you are marketing the product under your own brand
  • Your label must be clear, legible, and securely affixed to the product or packaging so it does not peel off during normal use or handling
  • Ensure that all required information (e.g., safety warnings, usage instructions) is included on your label and in the correct language(s) for the markets you are targeting
  • OEM Traceability: You must still keep internal records of the OEM's details (e.g., purchase orders, batch numbers) for traceability and regulatory purposes, even if their name is not visible to consumers.

Made in...

When (voluntarily) including a Made in... statement, it has to be accurate: In the EU, the Union Customs Code (UCC) governs origin labeling in the EU. A product's origin is determined by where it undergoes:

  1. A significant transformation that changes its nature or purpose, or
  2. A value-added process where a certain percentage of materials or work originates locally.

Repackaging and rebranding alone, would not qualify as a substantial transformation. This could lead to the interesting situation, that the VAR in the Netherlands would become the manufacturer, but that the products are still e.g., Made in China.

Amazon Pan-European FBA

Using Amazon's Pan-European FBA warehouse, means that all goods for sale through FBA, are delivered to one warehouse (In France in our case). Amazon seems to suggest that we only need to provide GPSR-related information in French, but that's probably not enough: These products will be sold through various European Amazon sites, so probably need labeling in languages corresponding to all EU Amazon sites (Amazon.co.uk is not part of the EU):

  1. Amazon.de - German
  2. Amazon.es - Spanish
  3. Amazon.fr - French
  4. Amazon.nl - Dutch
  5. Amazon.it - Italian
  6. Amazon.pl - Polish

You can easily see if your products are available on multiple Amazon marketplaces: Just check the ASIN on various sites.

Examples

Runcci-Yun

https://www.amazon.fr/RUNCCI-YUN-Connecteur-raccorder-Enceintes-ampli-Tuners/dp/B0C27F61MB

Scroll down to link Images et contacts de sécurité to open a sidebar with what seems to be all GPSR-related information:

  • An image of the package with the usual FBA label
  • An image of the other side of the package, with a label with GSPR-specific information
  • Contact information manufacturer
  • Contact information RP

These technical products - Resulting documents

As mentioned at the top of this article, this article was developed with certain specific technical parts in mind, primarily for Amazon/FBA.

More about the context:

  • Amazon pan-European FBA sales through Amazon.fr
  • Quick-and-dirty first: It may take time for Amazon to verify changes that we made. Hence we want to get it out ASAP. Maybe later we'll do stuff more elaborate.

Labeling

  • These are products that are already re-labeled with Amazon's FNSKU + bar code because of FBA
  • It would be nice if all compulsory additional information, fits on the labels that are already used - So far, this is the case while using 6 points font for the details. This is usually considered the smallest reasonable font size
  • Distinguish between what has to be included on the label, and what can be included elsewhere: On listings and website.

Language

Only in French

CE marking

Not needed as these are parts.

Made in...

  • Not needed, as not compulsory within the EU and sales is only through EU-oriented marketplaces
  • If we would include a Made in statement, the country would be the country where the OEM produced these goods. Despite white-labelling and being designated manufacturer, this doesn't change as no substantial change to the products are made by the VAR.

Manufacturer, RP & importer

  • The company is both the manufacturer and the RP - No person's name - Just the name of the company
  • All documents that the RP is supposed to have, are already available
  • Importer: Not relevant.

Product identifier

  • We keep using the FNSKU that is already included on the label
  • Optionally extend later with SKU, SKU-OEM and/or EAN.

Safety information labeling

The warnings below, could be condensed into a couple of short lines:

Safety information to include on the label
Requirement Notes
Choking hazard Unclear if needed, as these parts are not intended for children. We decided to include a standard sentence, because (1) these parts look funny and seem inviting to play with; (2) About 50% is sold to business and 50% to consumers. When stuff is delivered through post to consumers, we can't guarantee that children won't be in contact with them
Unplug device before replacement
General suitability General dimensions & fit, compaired to previous part
Verify correct functioning after installation
Disposal guidelines

Amazon Compliance Documents

Various Amazon Compliance Documents
Requirement Notes
Installation manual/notes
  • Information concerning unplugging & general fit → Safety information
  • Other info → Amz product listings and website
Instructions for use Hardly needed, as these are parts rather than things to directly use:
  • General compatibility → Safety notes
  • When to replace → Listings & site
Patient fact sheet Not needed
Provider fact sheet Not needed
Safety information See earlier section
User guide Relevant:
  • Safety-related information → See there
  • Other stuff already covered → Listings & site
User manual Not needed
Editing an article. Select Suggest changes to product information to access root information (seller-independent information)
Editing an article. Select All attributes to be able to select the tab Safety & Compliance. This is just the header of the screen
The same article. We uploaded a user guide - instructions d'ultilisation in the given language, including a link to the PDF version of this document in our usual media location (something like https://media.example.nl/gpsr/Mode-demploi-widgets.pdf

Amazon - Evaluate the results

How to know if it works out? Amazon is notoriously unclear and slow about processing changes and indicating results. This was about our pilot product: Updated on Friday, and appearantly succesful on Monday:

What How Results Notes
Inventory » Find the product » Check for errors Manage All Inventory » Search for the FNSKU » Improve listing quality Something about missing weight, but not about GPSR - Sounds good
Regulatory compliance » Find the product Performance » Account Health » Regulatory compliance » Search for the FNSKU "Zero policy violation warnings" - Sounds good
Check "compliance images" Search for the product » Display » Safety and Product Resources » Product Safety Related Images There are images of products in packages & labels
  • I can see them when going to the regular product om Amazon
  • I can't find these pictures anywhere in the backend - Weird.

A couple of more Amazon test products

Testproduct selection

Go to Product Policy Compliance, sort by "At-risk sale" » Dig deeper » Select ASIN

GPSR status, prior to update

There are two places where you can figure out the status, and they offer different dialogs to fix the problem. Probably, in the end this is just the same solution, but it's quite weird nevertheless

  • Product Policy Compliance page. Error: GPSR: manufacturer contact details
  • Inventory page: No error
  • Product Edit Page: Some GPSR data is missing - See image
All GPSR-related information at the Product Edit Page. I suspect that the user's manual is included by default. Only two questions to be answered - What could go wrong?

Update...

As mentioned before: You can fix (probably the same) problem at different places. Here illustrated by fixing two different products in these two ways:

Fix (1) - Product Edit Page: Updated the two GPSR-related setting (I couldn't resist clicking on 'Yes' concerning the question about global shipping - not related to GPSR). P.s.: The answer at GPSR Safety Attestation is probably wrong
Result of Fix (1) - Looks promising
Fix (2) - Product Policy Compliance Page » Submit: Choose the correct manufacturer from the two that are associated with your Amazon account (or add a new one) - This probably has the same effect as entering the manufacturer's email address in the previous screen
Result of Fix (2) - Looks promising. BTW: The email address is now also inserted at the Product Edit Page

Amazon: Set some account-wide settings

Since somewhere near the end of November 2024, you can specify Manufacturer and RP for each brand that you represent, for all associated products in your account. Go to Seller Central » Performance » Account Health » Downright: Submit compliance information.

Do this first - This will safe a lot of work.

Amazon fields

Only fields that are relevant to me, are included here:

Name Static field code Example dynamic field code Notes
ComDocs - instructions_for_use -- compliance_media[marketplace_id=A13V1IB3VIYZZH][content_language=fr_FR][content_type=instructions_for_use]#1.source_location Static fields don't seem to exist for ComDocs
ComDocs - installation_manual -- compliance_media[marketplace_id=A13V1IB3VIYZZH][content_language=fr_FR][content_type=installation_manual]#1.source_location Static fields don't seem to exist for ComDocs
ComDocs - safety_information -- compliance_media[marketplace_id=A13V1IB3VIYZZH][content_language=fr_FR][content_type=safety_information]#1.source_location Static fields don't seem to exist for ComDocs
ComDocs - user_guide -- compliance_media[marketplace_id=A13V1IB3VIYZZH][content_language=fr_FR][content_type=user_guide]#1.source_location Static fields don't seem to exist for ComDocs
country_of_origin country_of_origin country_of_origin[marketplace_id=A13V1IB3VIYZZH]#1.value
gpsr_manufacturer_reference gpsr_manufacturer_reference
  • Source: Product uploader file "TOOLS.xlsm" (2024.11.26) » Sheet Data definitions
  • Provide the reference email ID for the manufacturer address from your registry
gpsr_safety_attestation gpsr_safety_attestation
  • Source: Product uploader file "TOOLS.xlsm" (2024.11.26) » Sheet Data definitions
  • Usage: Check “yes” if your product doesn’t have any warning and safety information, as it can be used safely and as intended without it
item_weight - Weight item_weight[marketplace_id=A13V1IB3VIYZZH]#1.value Sometimes, weight and weight unit are included within the Safety & Compliance group on sheets, and therefore, also in Safety & Compliance related errors and warnings
item_weight - Unit item_weight[marketplace_id=A13V1IB3VIYZZH]#1.unit
ships_globally ships_globally
  • Source: Product uploader file "TOOLS.xlsm" (2024.11.26) » Sheet Data definitions
  • "Provide whether the item can be shipped globally by Amazon"
  • I don't know why this field usually is included in the Safety & Compliance group on sheets
other_image_url_ps01 - other_image_url_ps06 other_image_url_ps01 - other_image_url_ps06
  • Source: Category Listing Report - Available since the end of Nov. 2024, specifically for GSPR compliance
  • GPRS-related "safety images"
  • These fields can easily be updated with .CSV upload files - contrary to ComDocs



In the previous section, it was shown how RP and Manufacturer can be specified per branch at once. The only remaining fields to update:

  • country_of_origin
  • gpsr_safety_attestation
  • other_image_url_ps01 - other_image_url_ps06. Different for each problem
  • The actual documents.

See also Velden (Amazon)

Reduce file complexity

Downloaded Listings Report come in the shape of Excel .xlsm files that are unnecessarily large and don't play nice with LibreOffice Calc (macros? dropdown controls), eventhough it usually is surprisingly smooth sailing. Some notes about making this smoother:

Don't convert: Don't convert .xlsm files to .ods: The files become much bigger and become quite impossible to load. LibreOffice appearantly can handle .xlsm files so well nowadays, that the resulting .xlsm files are processed by Amazon without problem!

Remove redundant tabs: All tabs can be deleted, except Template - Modèle, Mall (Swedish), Modello (Italian) Plantilla (Spanish), Sjabloon (Dutch), Szablon (Polish), Vorlage (German).

Remove redundant columns: Remove columns that are not needed. So far, I keep the first three columns: contribution_sku, record_action and product_type, but from there, only what is relevant for the job at hand.

Simplify content A1

Cell A1 contains about a screenfull of data - Quite weird. Here is the summary of it:

settings=attributeRow=5&attributeSettings=%3D
&contentLanguageTag=fr_FR
&contributorId=amzn1.cr.o.AM7ZAOG60HOHI
&dataRow=7
&feedType=256
&flavor=full-seller
&headerLanguageTag=fr_FR
&isEdit=false
&isProcessingSummary=false
&labelRow=4
&listingsItemRequirement=LISTING
&primaryMarketplaceId=amzn1.mp.o.A13V1IB3VIYZZH
&productTypeRequirement=LISTING
&ptds=VE9PTFM%3D
&reportProvenance=false
&templateIdentifier=cbf0f9c7-4e41-403b-8e7e-55c8a9afa2aa
&timestamp=2024-11-22T11%3A15%3A04.940Z
&vendorCodes=W10%3D
&TemplateType=unified
&Version=2024.1122
&TemplateSignature=VE9PTFM=&umpVersion=MS4zMy41MTc=

And now the fun part: When I reduce this to just TemplateType=unified&Version=2024.1122 and remove the second row, the file gets accepted - Except for Amz asking what kind of file this is.

Unfortunately, nothings gets processed:

90008 - Fatal - The file's header row is missing or invalid. The header row is for Amazon use only and must not be modified or deleted. To correct this error, download the template again from seller Help and use that new copy, or insert the correct header row directly above the column headings in your existing file.

Amazon: Spreadsheet bulk-update

At the end of November 2024, Amazon created a GPSR-related report: Category Listings Report (Seller Central » Reports » Inventory reports)

Questions

  • OK - How about when a reseller uses its own EANs and effectively, becomes producer?
  • OK - How to track products from different manufacturers that we sell under the same VAR EAN code?
  • OK - Where does it come from, that you're supposed to include photos of the GPRS-compliant package and/or label?
  • OK - Where are the uploaded GPSR-related photos at the backend? » Nowhere, it seems. You can only see them at the frontend
  • OK - Can you really only upload only one Amazon Compliance Document per product? » No: See screenshot at the end of the "Requirements" chapter.

See also

Sources

General

Amazon - Itself

https://sellercentral-europe.amazon.com/help/hub/reference/external/GQAYBJPNAZ2LMDDT?ref=GPSR_email_gpsrhp

Amazon - About