GPSR and promotional products: what companies must know about safety

Since 13 December 2024, the General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) has applied across the European Union. It also covers the branded mugs, power banks, reflectors and other items a company hands to clients, partners or trade-fair visitors – even when they are given away rather than sold. This guide explains when a company becomes a "manufacturer" in product-safety terms, what must appear on the product and which questions to ask your supplier before you order.

Well-chosen corporate gifts build trust. An unsafe or incorrectly labelled item does the opposite and can even force you to recall a whole batch. The good news: most requirements are easy to meet if they are on the table at the start of the order.

In short

• The GPSR has applied since 13.12.2024 and replaced the former General Product Safety Directive 2001/95/EC. It is directly applicable in every Member State.
• It also covers items handed out for free: under the European Commission's guidelines, making a product available means supplying it in the course of a commercial activity "whether in return for payment or free of charge".
• If your company markets a product under its own name or trademark, manufacturer obligations may arise – the Commission's guidelines use a branded mug as their example.
• The product, its packaging or an accompanying document must show a type, batch or serial number, the manufacturer's name and trademark, and a postal and electronic address.
• Safety information and instructions must be in Estonian for consumers in Estonia when the product cannot be used safely without them (TTJA, the Estonian Consumer Protection and Technical Regulatory Authority).
• Items that attract children, resemble food, contain batteries or touch the skin need the most thorough confirmation from the supplier.

What the GPSR is and why it matters for corporate gifts

The GPSR is a general safety net for products intended for consumers or likely to end up with them, where no sector-specific EU law applies – and for the risks that sector-specific law does not cover. The official text is on EUR-Lex. The European Commission's Access2Markets overview notes that the regulation covers new, used, repaired and refurbished products, including those sold online.

For promotional products one sentence in the Commission's guidelines for businesses (C/2025/6233), published on 21.11.2025, is key: making a product available on the market means supplying it in the course of a commercial activity "whether in return for payment or free of charge". A mug you hand to a conference visitor is therefore not "just a gift" in product-safety terms. It is a product reaching a consumer, and it must be safe and traceable.

Items intended purely for business customers are not automatically excluded either. According to the guidelines, products designed for professional use fall within scope once they reasonably reach consumers. A power bank sent to the office and taken home by an employee is a typical case.

Who is responsible: manufacturer, importer, distributor and responsible person

The GPSR allocates obligations by role, and one company can hold different roles for different products. The Commission's guidelines describe a reseller that is a distributor for products it resells unchanged, but a manufacturer for products it rebrands and sells under its own name.

Does adding your logo make your company the manufacturer?

The Commission's guidelines describe a case where company B produces mugs and company A brands them with its logo and sells them to consumers. The conclusion: company A becomes the manufacturer of those mugs and is subject to the manufacturer's obligations under the GPSR. The example concerns sales, not free distribution, and the guidelines do not deal with promotional gifts specifically. So it cannot be said that every logo item automatically turns the buyer into a manufacturer. But if you plan to sell products under your own brand (in a web shop, as fan merchandise or club goods), expect manufacturer obligations and seek legal advice if needed.

In practice the simplest route is for the actual manufacturer or EU importer to remain in the manufacturer role, with its details and batch number on the product or packaging. Agree on this with your supplier in writing at the quotation stage.

What must appear on the product, packaging or accompanying document

The Commission's guidelines list the manufacturer information that must appear on the product, its packaging or an accompanying document:

1. A type, batch or serial number or another element allowing the product to be identified.
2. The manufacturer's name and registered trade name or trademark.
3. A postal and an electronic address. The electronic address can be an e-mail or a website contact form; a website address alone is not enough.
4. Details of the EU responsible person if the manufacturer is based outside the EU. An EU-based manufacturer can act as its own responsible person.
5. The importer's name, trademark and addresses if the product comes from outside the EU.
6. Instructions and safety information – only where the product cannot be used safely without them.

Information may be moved from the product to the packaging or a document only when the product's physical size requires it. According to the guidelines, aesthetics is not a valid reason. For promotional items this is a practical point: a designer's wish for a "clean" product does not justify dropping the batch number if it fits on the item.

Language: Estonian in Estonia

The language of instructions is set by the Member State where the product is placed on the market. TTJA's 2025 seminar materials are clear: information must be given in a language consumers easily understand – for consumers in Estonia, in Estonian. If you hand out the same item at an event in Finland or Latvia, you need that country's language.

Higher-risk promotional products

Under the Commission's guidelines, manufacturers must pay particular attention to consumers in vulnerable situations: children, older people and persons with disabilities. Products that may attract children or resemble food must be assessed even if they are not intended for children, and age labelling may be needed. In a promotional range this means:

• Items for or attractive to children – soft toys, stress balls, colourful small items and anything resembling sweets. Toys are also subject to separate toy safety rules and CE marking; ask the supplier whether the item is a toy and which declaration of conformity applies.
• Battery-powered electronics – power banks, speakers and lights, which have their own electrical equipment requirements. TTJA points out that instructions for ordinary consumers must be in Estonian. Browse our electronics category together with the supplier's documents.
• Food-contact items – bottles and mugs, chopping boards and boxes, which are also covered by food contact material rules.
• Textiles worn on the skin – T-shirts, hats and towels. Ask for fibre content labelling and, where possible, a certificate such as OEKO-TEX.
• Lanyards and cords – for events for children and young people, ask for a version with a safety breakaway.

What to ask your supplier before ordering: checklist

Add these questions to your request for quotation so the answers arrive with the offer and you do not have to chase them during production.

1. Who is the manufacturer of this product under the GPSR, and whose name and address will go on the product or packaging?
2. Does the product come from outside the EU? If so, who is the importer and the EU responsible person?
3. How is traceability ensured – does every product or package carry a batch or type number?
4. Can the product be used safely without instructions? If not, are the instructions and warnings in Estonian (and in the languages of other target countries)?
5. Is the product a toy, electrical equipment or a food contact material? Which declaration of conformity or test report is available?
6. Has the manufacturer carried out a risk analysis, and is the technical documentation available to the authorities on request?
7. Does the decoration method (e.g. UV printing, engraving or textile printing) affect the product's safety or its food-contact surface?
8. What will the supplier do if a hazard is discovered – who notifies the authority and how does a recall work?

At Logotrade we request this information from suppliers while preparing the quote and note where it sits on the product. We choose the right decoration service so that it does not cover mandatory markings. You will find the full range in our product catalogue.

Example: family-day giveaways

Example: a company is organising a family day and wants to give 300 visitors a bag with a branded water bottle, a soft toy and a reflector. All three items will reach consumers, including children.

1. Risk screening. The soft toy is intended for children and is therefore a toy. The bottle is in contact with food. The reflector has its own standard and marking.
2. Supplier request. The checklist questions are asked for each item; for the toy, CE marking, age warning and declaration of conformity are requested separately.
3. Placement of markings. The bottle's batch number and manufacturer details are on the base, the logo on the side. The toy has a sewn-in label that the logo does not cover.
4. Language. The toy warning and the bottle care instructions are in Estonian on a card inside the bag.
5. Records. The company stores the supplier documents and batch numbers. If a batch problem emerges later, it knows where and how many items were handed out.

This routine does not noticeably lengthen the project, but it avoids a situation where nobody knows after the event who made the product or which batch it came from.

If something goes wrong: accidents, notifications and recalls

The GPSR brought business notifications together in one place: the Safety Business Gateway. According to the Commission's notice (C/2025/6238), the manufacturer reports accidents causing death or serious adverse effects on health through it "without undue delay". Importers and distributors inform the manufacturer. If a distributor considers a product dangerous or finds it lacks identification information, it must ensure the authorities are informed immediately.

Where a recall is necessary, consumers must be offered an effective remedy free of charge. According to law firm Fieldfisher, this means at least two of three options: repair, replacement or refund. A recall notice must not downplay the risk with words such as "voluntary" or "precautionary". Warnings about dangerous products in Europe are published in the public Safety Gate system, which replaced the former RAPEX.

For a buyer of promotional items this means knowing where the products went. A simple table of event, quantity and batch number is enough to find recipients if a recall ever happens.

Common mistakes

• "It's a free gift, the rules don't apply." Under the Commission's guidelines, making a product available includes free supply in the course of a commercial activity.
• Sacrificing the batch number for the design. Aesthetics is not a reason to remove mandatory information from the product.
• English-only warnings. For consumers in Estonia, safety information must be in Estonian.
• The cheapest web offer with no EU contact. If there is no responsible person established in the EU behind the product, the authorities will look to the next link in your chain.
• Adult giveaways at a children's event. Small parts and cords need extra checks.
• Not keeping documents. Manufacturers and importers must keep documentation for 10 years. As a buyer you only need the supplier's details and batch numbers – but keep them.

More practical guides on quality, electronics and product origin are on our blog. It is also worth looking at products made in Estonia, where the manufacturer is close by and documents are easy to obtain.

Frequently asked questions

Does the GPSR apply to products we give away rather than sell?

Yes, if they reach consumers. Under the Commission's guidelines, making available means supplying in the course of a commercial activity, whether for payment or free of charge.

Are items handed out only to employees covered?

An employee uses a gifted travel mug or power bank like any consumer, so it is sensible to apply the same requirements. Items intended only for work (e.g. personal protective equipment) are subject to their own rules.

Does every pen need a batch number?

Identification information must be on the product. If the product is too small, it may be on the packaging or an accompanying document. Agree the exact solution with your supplier.

Can a QR code replace printed information?

No. Digital information can supplement physical labelling but cannot replace it.

Who supervises product safety in Estonia?

The Consumer Protection and Technical Regulatory Authority (TTJA). In Estonia the GPSR has been implemented through amendments to the Product Conformity Act.

What should we do if a product we handed out turns out to be dangerous?

Inform the supplier and manufacturer immediately and gather data on where and when the products were distributed. Dangerous products are reported to the authorities through the Safety Business Gateway.

Logotrade's experience

Logotrade OÜ has operated in Tallinn since 2004, helping companies choose, design and order branded gifts. We are a member of the international promotional products networks PSI and ASI and of the Estonian Chamber of Commerce and Industry. Product safety questions are a routine part of every quote we prepare. You can see completed projects in our portfolio.

Send your idea, target group and quantity to logo@logo.ee or use our contact page. In the quote we will confirm lead time, minimum quantity, price and which safety documents come with the product.

Sources

• Regulation (EU) 2023/988 on general product safety, EUR-Lex
• European Commission guidelines on the application of the GPSR by businesses (C/2025/6233)
• Commission notice on the Safety Business Gateway (C/2025/6238)
• TTJA seminar materials on product safety (2025, in Estonian)
• Access2Markets: the EU General Product Safety Regulation
• Fieldfisher: GPSR recall duties for businesses