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What Does the EU GPSR Mean for Importers of Wooden Home Products?

By Ninghai Bohong Arts & Crafts Co., Ltd.

A wooden shelf, tray, box or bamboo organiser sold to EU consumers falls under the General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, which has applied since 13 December 2024. It needs an internal risk analysis and technical documentation, a type, batch or serial number, the manufacturer’s and importer’s names with postal and electronic addresses, and an economic operator established in the EU who is responsible for it. There is no GPSR certificate, and this regulation does not call for CE marking.

This guide explains who does what when you buy from a factory in China, what the label and online listing must show, what to ask your supplier, and how Ninghai Bohong Arts & Crafts Co., Ltd. handles each point. It is general guidance as of November 2026, not legal advice; check your own case with your compliance adviser.

Which wooden products does the GPSR cover?

The GPSR covers items intended for consumers, or likely to be used by consumers under reasonably foreseeable conditions, as far as no specific EU safety rules with the same objective apply. Most wooden and bamboo home goods have no product-specific EU safety law, so the GPSR is the main safety rule for them.

Product groupHow the GPSR applies
Shelves and desks, home goods and boxes, bamboo home goodsIn full: general safety requirement, documentation, identification, responsible operator
Garden and outdoor productsIn full; outdoor use is part of the foreseeable use you assess
Goods you sell only to retailersStill covered if the item ends up with consumers, or is likely to
Wooden toysThe Toy Safety Directive 2009/48/EC comes first; the GPSR only reaches risks that directive does not cover. See EN 71 for wooden toys
Items meant to touch foodSeparate EU rules also apply and are outside this guide; Bohong makes no such claim for its trays and boards

The GPSR also applies in Northern Ireland. Great Britain stays under the General Product Safety Regulations 2005.

Who is responsible: the factory, the importer or your brand?

It depends on whose name is on the product. Under Article 13, anyone who places a product on the market under their own name or trademark is treated as the manufacturer and takes on the manufacturer’s duties in Article 9. For a private-label buyer, that usually means your company, even though the factory built the product.

Your set-upWho counts as manufacturerYour main duties
You import and sell under your own brandYour companyRisk analysis, technical documentation, identification, labels, instructions (Article 9)
You import and sell under the maker’s nameThe makerCheck the maker’s documentation and labels, add your own name and address, keep a copy of the documentation (Article 11)

Separately, Article 16 says a product may not be placed on the EU market unless an economic operator established in the EU is responsible for it. That can be an EU manufacturer, an importer, an authorised representative with a written mandate, or a fulfilment service provider. Bohong is based in Ningbo, China, so it cannot fill this role; your company or your representative does.

What must appear on the product, the packaging and the online listing?

InformationWhere it goesArticle
Type, batch or serial number or similar identifierOn the product, visible and legible; on the packaging or an accompanying document only if size or nature does not allow it9(5)
Manufacturer’s name, postal and electronic addressOn the product; if not possible, on the packaging or an accompanying document9(6)
Importer’s name, postal and electronic addressSame rule, and it must not cover the manufacturer’s label11(3)
Responsible operator’s name and contact detailsOn the product, packaging, parcel or an accompanying document16(3)
Clear instructions and safety informationWith the product, in a language set by the country of sale; not needed if the product is safe to use without them9(7), 11(4)
Manufacturer, responsible operator, picture, type or identifier, warningsClearly and visibly in the online offer19

At Bohong, label text is part of the packing specification. We can print your artwork on cartons, inserts, bags or sleeves, and engraving is done in our own workshop. Send the exact wording and position with your request; how and where it is applied is confirmed with your quote. See the RFQ checklist and Packing & shipping.

What goes into the risk analysis and technical documentation?

Article 9 sets a minimum: a general description of the product and its essential characteristics relevant to safety. Where the risks call for it, add an analysis of possible risks and the solutions adopted, any test reports, and the European standards applied. Manufacturers and importers keep this for 10 years after the product is placed on the market and show it to market surveillance authorities on request.

Article 6 lists what a safety assessment looks at, including design, composition, packaging, assembly instructions, labelling, and vulnerable consumers such as children and older people. For wooden goods, these are practical questions to work through. They are our suggestions, not a list from the regulation:

  • Shelves and wall-mounted items: load in normal use, fixings, whether the item can tip.
  • Folding items: locking, pinch points, and what happens if it is set up wrongly.
  • Surfaces: edges, splinters, and what the finish is made of.
  • Children nearby: small detachable parts, and whether a child is likely to climb on it, even if it is not a toy.
  • Damp and outdoor use: how wood, joints and fixings behave in a bathroom or a garden.

What does Bohong supply, and what stays with your company?

TaskBohongYour company
Product descriptionSpecifications and packing in writing with your quote; species and availability confirmed per projectApprove them and use them in your documentation
FinishBamboo: usually a clear lacquer or a natural oil finish; water-based lacquer on request. The finish for your order is confirmed with your quoteAssess it for your use and market
TestingAny load test your market requires is arranged per order. Toys: EN 71-1, -2, -3 reports for two tested modelsDecide which tests your risk analysis needs
Risk analysis and technical documentationThe product information we supply for it is confirmed with your quoteOwned by the manufacturer: your company if the brand is yours
EU responsible operatorNot possible; Bohong is not established in the EUYour company or your representative

For outdoor items, a product can be finished with an outdoor wood oil or stain. Tell us the climate and how it will be used, and we confirm the finish with your quote.

What should you ask a wooden-products supplier before ordering?

  1. Which materials, finish and fittings are used, in writing?
  2. Where can the identifier and the addresses go on the product, and at what stage are they applied?
  3. Which test reports exist for this exact model, and which would have to be arranged?
  4. Which instructions or warnings do you already have, and can they be supplied in our languages?
  5. How do you keep series production in line with the approved sample?
  6. Who do we contact if a safety problem is reported after sale?

Send us these questions with your product list through the contact page. For custom work, see OEM / ODM & custom; our certificates are listed under Certifications.

FAQ

Is there a GPSR certificate?

No. The regulation does not create a certificate, and Bohong does not claim one. Compliance is shown through the risk analysis, the technical documentation and correct labels.

Can the factory in China be our responsible person?

No. Article 16 requires an economic operator established in the EU. A factory in China can supply product information, but your company or a representative in the EU takes this role.

Does the GPSR apply if we sell only to retailers?

Usually yes, if the product is intended for consumers or is likely to reach them. Check your own case with your compliance adviser.

How long do documents have to be kept?

Manufacturers and importers keep the technical documentation for 10 years after the product is placed on the market.

Do wooden toys need GPSR documents as well?

Toys follow the Toy Safety Directive first, and the GPSR only reaches risks it does not cover. Two Bohong models have EN 71 reports. Testing for a new model is arranged per order with a third-party laboratory; we have worked with Bureau Veritas and DL Testing. We do not claim EN 71 or CE for models without a test report.

What happens if a product turns out to be dangerous?

The manufacturer must take corrective measures, including withdrawal or recall where appropriate, inform consumers, and inform the authorities through the Safety Business Gateway. An importer must inform the manufacturer and make sure the authorities are told.

Sources

Official and public sources used for this guide.

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