General Product Safety Regulation (GPSR) in online parts sales: mandatory information for new, used and remanufactured parts

Since 13 December 2024, Regulation (EU) 2023/988 on general product safety, the GPSR, has applied directly in every Member State. In online parts sales one article is felt above all: Art. 19 sets out the minimum information a distance-sales offer must contain. The regulation expressly covers new, used, repaired and reconditioned products. Parts dealers, workshop shops, car dealerships and dismantlers with marketplace listings can therefore all be affected. This article explains what that means for vehicle parts. Warranty and withdrawal are covered in Liability for defects on used parts: what applies and what does not, approval documents in Type approval, general approval and expert reports: what each paper means.

When a vehicle part falls under the regulation

The GPSR covers products intended for consumers or likely, under reasonably foreseeable conditions, to be used by consumers even if not intended for them (Art. 3(1)). According to the Commission guidelines, this includes products initially designed for professional use that have later migrated to the consumer market. Online sales add a second point: a product offered online is considered made available on the market if the offer is targeted at consumers in the Union, and that is determined case by case (recital 21). Relevant factors named there include the dispatch area, language, means of payment, currency and domain name; the mere accessibility of a website in the consumer’s country is not enough. Whether a channel that supplies only workshops and traders therefore falls outside Art. 19 is not expressly answered by the text of the regulation — the definition of product refers to the product, not to the sales channel. This classification comes before the question of which fields the offer needs.

New, used, repaired, reconditioned — and the one exception

Relationship with type approval

Under Art. 2(1), the GPSR applies only insofar as Union law contains no specific provisions with the same objective. For motor vehicles and their systems, components and separate technical units, Regulation (EU) 2018/858 governs approval and market surveillance. It is listed as no. 69 in Annex I to Market Surveillance Regulation (EU) 2019/1020 and is therefore Union harmonisation legislation within the meaning of Art. 3(27) GPSR. For products subject to specific requirements of such legislation, Art. 2(1) excludes parts of the GPSR — but not all of them. Since 29 May 2026, as amended by Regulation (EU) 2024/2748, this also covers the new Chapter IIa on emergency procedures; that does not change the parts in the table below.

For the trade, this means the information requirement of Art. 19 also applies to the online offer of a part subject to sector-specific requirements — this is how the Commission guidelines classify it in section 2.2. Whether that is the case for a given part has to be clarified part by part; an approval mark on the part is an indication, its absence is no proof of the opposite. The text of the regulation leaves open how point (b) is to be completed for such parts: it refers to the responsible person under Art. 16(1), which belongs to the excluded Section 1, or under Art. 4(1) of Regulation (EU) 2019/1020, whose paragraph 5 does not list Regulation (EU) 2018/858, including in the version of 12 August 2026. A business should clarify this with its supplier or legally rather than assume an answer.

The four items in the offer

Used parts placed on the market before 13 December 2024

A used part may come from a vehicle built before the date of application. Art. 51 provides that Member States shall not impede the making available on the market of products covered by the former Directive 2001/95/EC that comply with it and were placed on the market before 13 December 2024. Placing on the market is the first making available on the Union market; according to the Commission guidelines it has to be determined for every individual unit of the product. As an example, the guidelines state that the new requirements to affix traceability and safety information to the product or its packaging do not apply to such units. At the same time, they state that the obligations of the regulation apply to any offer of products made on or after 13 December 2024.

In its seller information, eBay expressly points to differing interpretations and, in its own understanding, reads Art. 51 to mean that for used items complying with the directive and placed on the EU or Northern Ireland market before 13 December 2024, no GPSR information such as manufacturer details is needed in the listing. It recommends keeping clear records of when products were first placed on the market. The two readings do not fully coincide. Anyone omitting the information should therefore record per unit what that is based on; anyone providing it is on the safe side under both readings, which eBay also suggests.

Remanufactured parts and substantial modification

Remanufactured parts sit between new and used parts; New, used, remanufactured, replica: four terms, two dimensions sets out the terms. The GPSR comes in at two points. Whoever places a product on the market under their own name or trade mark is deemed the manufacturer under Art. 13(1) — a remanufacturer with its own brand then belongs in point (a) itself. Whoever substantially modifies a product is subject to the manufacturer’s obligations under Art. 13(2) for the part affected or for the entire product if the modification has an impact on safety. Under paragraph 3, a modification is substantial where it has an impact on safety, was not foreseen in the initial risk assessment, changes the nature of the hazard, creates a new hazard or increases the level of risk, and was not made by consumers themselves or on their behalf for their own use. Art. 13 sits in Chapter III, Section 1 and is therefore excluded for parts subject to specific requirements of harmonisation legislation.

What marketplaces ask for as a result

Providers of online marketplaces have obligations of their own under Chapter IV, which also apply to products with sector-specific requirements. Under Art. 22(9) they design their online interface so that traders can provide at least the Art. 19 information for each product and that it is displayed to consumers on the product listing or otherwise easily accessible. Under paragraph 10, their internal processes include mechanisms through which traders provide this information and, where applicable, a self-certification. Under paragraph 11, they suspend their services for a reasonable period, after a prior warning, for traders that frequently offer non-compliant products. Because these two obligations specify obligations under the Digital Services Act, the guidelines state that they apply only to medium-sized and large enterprises and to micro and small enterprises designated as very large online platforms or search engines.

That is why the information appears as separate fields on marketplaces. eBay, for example, requires business sellers listing in the EU and Northern Ireland to provide the manufacturer’s name and contact information, an EU-based responsible person where the manufacturer is located outside that area, product information such as model number, pictures and type, warnings and safety information in the local language, and the CE marking where required. If the information is missing, listings may not be visible or purchasable for buyers there. Keeping these values as separate fields in your own stock rather than in the description text means maintaining them once and feeding them to every channel — see Stock data for marketplaces: why good parts still are not found for the field logic.

Workflow in the business

1. Define the type of part: new, used, repaired, reconditioned or explicitly for repair or reconditioning — and mark the offer accordingly.
2. Clarify the framework: is the channel targeted at consumers in the Union, and is the part subject to sector-specific requirements?
3. Capture identifiers: photograph the label, extract it and confirm the number — see Image recognition in the yard: reading type plates and part numbers.
4. Determine the manufacturer: establish the manufacturer within the meaning of the regulation and take the postal and email address from the product, packaging, accompanying document or supplier; for manufacturers outside the Union, the responsible person.
5. Carry over safety information: warnings and safety information that must accompany the part, in the language set by the Member State of the target market.
6. Keep fields and records: maintain the information as separate fields in your stock and document per unit what any omission is based on.

This article is general professional guidance and does not replace legal advice. The applicable statute and the conditions imposed by your competent authority prevail.