amfori has responded to the Commission’s request for feedback on the General Product Safety Directive (GSPR).
In general, we welcome the proposed GPSR as a way of ensuring that products on the market are safe and that procedures are in place when unsafe products reach the marketplace. The enhanced coherence with other, similar, areas is appreciated, as are the improvements to coordination and the provisions on enforcement.
We stress that many importers/retailers already have procedures in place that are compliant with the proposed regulation but raise concerns that certain requirements could place an additional burden on some importers – although this is a necessary consequence of achieving the desired outcome. In particular, the requirement that insists an importer must ensure the manufacturer is in compliance with its requirements.
It also appears that the requirements placed on on-line marketplaces are less demanding than those placed on importers. This gives them an unfair advantage over those importers/retailers and may provide the possibility that unsafe products will reach the marketplace. We therefore ask that the requirements are brought more into line with those imposed on importers.
Stuart Newman, Senior Legal Advisor – Sustainable Trade & Customs