When the General Product Safety Regulation took effect in December 2024, a large amount of advice arrived with it, and most of it said the same thing: if you sell into the European Union from outside it, appoint a responsible person there.
Some of that advice was right. Some of it skipped the question the Regulation itself asks first, which is whether the product is covered by it at all. For cable, that question has a specific answer written into the text, and it sits in an article most summaries never quote.
What the Regulation is
The instrument is Regulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety. It amends Regulation (EU) No 1025/2012 and Directive (EU) 2020/1828, and it repeals Directive 2001/95/EC, the older General Product Safety Directive, together with Council Directive 87/357/EEC.
Its application date sits near the end of the text: the Regulation enters into force on the twentieth day following publication in the Official Journal, and it applies from 13 December 2024.
Article 1 sets out what it is for. It aims to improve the functioning of the internal market while providing for a high level of consumer protection, and it lays down essential rules on consumer products placed or made available on the market. That word carries most of the weight in everything that follows.
Article 3(1) defines a product as any item, whether or not interconnected to other items, supplied or made available, including in the context of providing a service, which is intended for consumers or is likely, under reasonably foreseeable conditions, to be used by consumers even if not intended for them.
The version matters for anyone checking this: the consolidated text read here is version 02023R0988 dated 29 May 2026, incorporating the amendment made by Regulation (EU) 2024/2748 of 9 October 2024. Consolidated texts carry their own disclaimer that they are a documentation tool with no legal effect, which is a reason to name the version when quoting one.
The scope questions the Regulation asks before any obligation attaches
The carve-out that changes the answer
Article 2(1) is the provision to read before anything else. It says the Regulation applies to products placed or made available on the market insofar as there are no specific provisions with the same objective under Union law which regulate the safety of the products concerned. Where products are subject to specific safety requirements imposed by Union law, the Regulation applies only to those aspects and risks, or categories of risks, which are not covered by those requirements.
It then goes further for one group. For products subject to specific requirements imposed by Union harmonisation legislation, as defined in Article 3(27), two things happen: Chapter II does not apply insofar as the risks covered by that harmonisation legislation are concerned, and a longer list does not apply at all.
Provision group | Position for products under Union harmonisation legislation |
|---|
Chapter II | Does not apply insofar as the risks covered by the harmonisation legislation are concerned |
|---|
Chapter IIa | Does not apply |
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Chapter III, Section 1 | Does not apply |
|---|
Chapter V | Does not apply |
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Chapter VII | Does not apply |
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Chapters IX to XI | Do not apply |
|---|
That table is the reason this article exists. The responsible-person duty sits in the Regulation’s Chapter III, Section 1, because that is where Article 16 appears in the structure of the text. If a product falls into the harmonisation category, that whole section is disapplied, and the duty in Article 16 is not one of the obligations that reaches it.
For a product whose safety is already regulated by specific Union law, in other words, the question is not who the responsible person will be. It is whether the Regulation applies to that product beyond the narrow residue that Article 2(1) leaves open, and whether Chapter III Section 1 was ever the right place to look.
Which provision groups Article 2(1) disapplies, and which remain
What Article 16 actually says
The responsible-person provision is worth reading in full, because its first words are a condition rather than a command.
Article 16(1) states that a product covered by this Regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020 in respect to that product. It then applies Article 4(2) and (3) of that Regulation to products covered by this Regulation, and provides that references to Union harmonisation legislation in Article 4(3) are to be read as references to this Regulation.
The opening condition is the part to notice. The obligation attaches to a product covered by this Regulation, not to every product sold into the Union.
Article 16(2) adds tasks for whichever operator takes the role. Without prejudice to any other obligations, and to ensure the safety of the product it is responsible for, that operator shall regularly check that the product complies with the technical documentation referred to in Article 9(2), and that it complies with the requirements in Article 9(5), (6) and (7). On request by market surveillance authorities, it must provide documented evidence of the checks it performed.
Where the provision does apply, it is not a form to file but an ongoing verification duty with an evidence trail.
The definition that catches private label
There is one provision in this Regulation that a cable seller should read regardless of where the scope question lands, and it is a definition rather than an obligation.
Article 3(8) defines a manufacturer as any natural or legal person who manufactures a product or has a product designed or manufactured, and markets that product under that person’s name or trademark.
Read the second and third limbs together. A party that does not manufacture anything, but commissions the product and sells it under its own name or trademark, meets the definition of manufacturer. For cable bought under a buyer’s own brand, that is the buyer.
The surrounding definitions make the structure clear, and they are not interchangeable.
Role | How Article 3 defines it |
|---|
Manufacturer (3(8)) | Manufactures a product, or has one designed or manufactured, and markets it under that person’s name or trademark |
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Authorised representative (3(9)) | A person established within the Union holding a written mandate from a manufacturer to act on its behalf for specified tasks |
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Importer (3(10)) | A person established within the Union who places a product from a third country on the Union market |
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Distributor (3(11)) | A person in the supply chain, other than the manufacturer or the importer, who makes a product available on the market |
|---|
That table is worth carrying into a private-label negotiation: the party whose name or mark goes on the product is the party the framework treats as responsible for it.
The record-keeping clock
Two retention periods in Article 15 are specific enough to plan around.
Article 15(4) requires economic operators to be able to present the information referred to in paragraph 2 for a period of 10 years after they have been supplied with the product, or after they have supplied it.
Article 15(5) sets six years for the information referred to in paragraph 3, and its wording extends to a part, a component or any software embedded in the product, as well as to the product itself.
Ten years and six years are long periods in a supply chain where purchase orders and certificates are usually archived by financial year. Where a framework does apply, the practical consequence is an archive requirement that outlives most commercial relationships, and one that has to be designed rather than improvised.
What to check before you appoint anyone
None of the following is legal advice; the Regulation is the authority. It is the sequence of questions the text suggests, and it is short.
- Is the product a consumer product on the Article 3(1) definition, or is it a component going into equipment? The Regulation’s purpose is stated in terms of consumer products.
- Is the product’s safety already regulated by specific Union law with the same objective? If it is, Article 2(1) determines how much of the Regulation reaches it at all.
- If specific Union harmonisation legislation applies, does that place the product inside the group for which Chapter III Section 1 is disapplied?
- Whose name or trademark is on the product? That answer decides who the manufacturer is under Article 3(8), independently of who ran the extruder.
- If obligations do apply, is there an economic operator established in the Union able to carry them, and does that operator have the mandate and the records that Article 16(2) requires it to be able to evidence?
The order matters. Working through the last question first is how a supplier ends up appointing a responsible person for a product whose obligations under this Regulation were never engaged, or alternatively, assuming that a nominated representative settles a question that Article 3(8) placed elsewhere.
FAQ
Do I need an EU responsible person for cable?
It depends on the product, and the Regulation says so. Article 16 applies to a product covered by the Regulation, and Article 2(1) restricts what the Regulation covers where specific Union law already regulates the product’s safety. For products under Union harmonisation legislation, Chapter III Section 1, which contains Article 16, is disapplied. Establish the scope first.
When did the Regulation start to apply?
It applies from 13 December 2024. It entered into force on the twentieth day following publication in the Official Journal, and the text states the application date separately.
Does GPSR still apply if another EU law already covers the product?
Article 2(1) applies the Regulation only insofar as there are no specific provisions with the same objective elsewhere in Union law, and for products under Union harmonisation legislation it disapplies several groups of provisions outright, with Chapter II retained only for risks the harmonisation legislation does not cover.
If I put my own brand on imported cable, am I the manufacturer?
On the Article 3(8) definition, a party that has a product manufactured and markets it under its own name or trademark is a manufacturer, regardless of who physically made it. That is a separate question from whether GPSR applies, and it needs answering in its own right.
Conclusion
The safest thing to do with a regulation this broad is to read its scope article before its obligations, and GPSR rewards that order. Article 1 says it is about consumer products. Article 2 says what it does not reach. Article 16, the provision behind most of the December 2024 advice, sits in a section Article 2 disapplies for products whose safety is already regulated elsewhere in Union law.
That does not make the Regulation irrelevant to anyone in the cable trade. It makes the order of the questions the thing that matters, and it makes Article 3(8) worth reading whichever way the scope question resolves.
Compliance documentation for cable programs
ZONG Cable supplies HDMI, USB, network, patch cord, fiber and communication cable and can provide the technical documentation a customer’s compliance process requires, including material declarations, test evidence and the construction detail that a technical file is built from. We do not give legal advice and we do not decide for a customer which regime applies to their product; what we can do is supply the documents accurately and consistently so that whoever does decide has the right material in front of them. The range sits under cable, the batch evidence is described on our test and inspection page, and OEM support covers how documentation is handled for private-label programs.
Sources
- Regulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety, consolidated text version 02023R0988 dated 29 May 2026, incorporating the amendment made by Regulation (EU) 2024/2748 of 9 October 2024. Articles read directly for this article: Article 1 objective and subject matter; Article 2 scope, including the disapplication of Chapter IIa, Chapter III Section 1, Chapters V and VII and Chapters IX to XI for products subject to Union harmonisation legislation; Article 3 definitions, including product, manufacturer, authorised representative, importer, distributor and economic operator; Article 15 paragraphs 4 and 5 on record retention; Article 16 paragraphs 1 and 2 on the responsible person; and the final article stating entry into force and application from 13 December 2024. https://eur-lex.europa.eu/eli/reg/2023/988/2026-05-29/eng
- ZONG Cable range. https://zh-zong.com/cable/
- ZONG Cable test and inspection. https://zh-zong.com/test-inspection/
- ZONG Cable OEM support. https://zh-zong.com/oem-support/
