Under the EU General Product Safety Regulation (GPSR), consumer jewellery sold in the EU needs an economic operator based in the EU who is responsible for its safety. If you import jewellery from India into the EU, that is usually you as the importer. If a non-EU seller ships directly to EU consumers, they need an authorised representative in the EU.
GPSR is Regulation (EU) 2023/988 and has applied since 13 December 2024. It sits alongside the chemical limits in REACH and does not replace them. Confirm how it applies to you with a compliance adviser.
Who counts as the responsible person for jewellery?
The regulation names the manufacturer, the importer, an authorised representative or, in some cases, a fulfilment service provider as the economic operator responsible. For goods made outside the EU, the importer is responsible unless there is an EU-based manufacturer or authorised representative.
That means a business that imports Indian jewellery in its own name takes on the duties. An Indian factory cannot fill this role unless it appoints an EU representative in writing.
What do the duties involve?
The main obligations for an importer of consumer jewellery are:
- Place only safe products on the market, and carry out an internal risk analysis for the product.
- Keep technical documentation, including the risk analysis and test evidence, for ten years after the product is placed on the market.
- Make sure the product shows a type, batch or serial number, and your name, postal address and electronic address, on the product, or on the packaging or an accompanying document if the product is too small.
- Provide safety information and warnings in the language of the country of sale.
- Report accidents and act on recalls through the EU safety systems.
How GPSR applies to small jewellery
Earrings and rings are often too small to carry text. In that case the identification can go on the packaging or a card. Plan this at the design stage, so the supplier prints your details on the hang tag or pouch. See barcode labels and hang tags printed in India.
Your risk analysis should address the realistic hazards of jewellery: chemicals, small parts for children, sharp edges, and allergens. Chemical limits are covered in the EU lead limit under REACH, and wider labelling in labelling requirements for imported jewellery.
Online marketplaces have their own duties under the regulation and may ask you to upload your details and test evidence.
Keep a file for each design. It should hold the specification, photographs, the risk analysis, test reports for the destination, the supplier's declaration of the materials used and a record of which production lot each report covers. If a market authority or marketplace asks for evidence, you can answer in a day instead of chasing the factory. Confirm the exact content of the file with a compliance adviser for your market.
How we help
The responsible person is a legal role that stays with you, and we do not take it on. What we can do is make sure the evidence you need exists: tested samples, matching production lots and correct marking on the packs. Book a free sourcing review to go through it for your range.