The EU General Product Safety Regulation (GPSR), Regulation (EU)
2023/988, has applied since 13 December 2024. It covers consumer
products sold offline and online and requires a responsible economic
operator established in the EU for products within its scope.
For brands selling pet collars, leashes, harnesses, horse rugs and
related consumer accessories, the finished product—not an isolated
buckle alone—is normally the key unit of risk assessment. Hardware
specifications and test records still matter because the buckle, snap
hook, ring or slider can be a safety-relevant component of that finished
product.
What the
regulation requires from manufacturers
Article 9 requires manufacturers to carry out an internal risk
analysis and prepare technical documentation containing at least a
general product description and essential characteristics relevant to
safety. Where appropriate, the file should include identified risks,
mitigation measures, test reports and the standards or other elements
used to support the safety assessment.
The technical documentation must be kept up to date and available to
market-surveillance authorities for 10 years after the product is placed
on the market. Products must also be identifiable by type, batch, serial
number or another element, with manufacturer contact information and
necessary instructions or safety information.
A practical technical-file
structure
| Section | Recommended content |
|---|---|
| Product identity | SKU, model name, photos, intended use, target user and product variants |
| Bill of materials | Webbing, thread, padding, hardware, labels and packaging |
| Controlled hardware data | Drawing, internal dimensions, material, finish, spring or gate details |
| Risk analysis | Foreseeable misuse, entrapment, breakage, sharp edges, corrosion, small parts |
| Verification | Dimensional inspection, assembly checks, load tests, corrosion tests where relevant |
| Traceability | Supplier, batch, approved sample, inspection record and production date |
| Consumer information | Warnings, use instructions, maintenance and replacement criteria |
| Corrective-action process | Complaints, incidents, investigation, withdrawal or recall workflow |
Hardware
data that improves the finished-product file
A component drawing should identify the functional dimensions,
material and finish. For a snap hook, record the gate opening, eye
width, swivel construction and spring function. For a buckle, define the
strap path, tongue engagement and edge requirements. For rings and
sliders, specify weld status and internal width.
Testing should reflect the finished application. A high component
breaking load does not compensate for weak webbing, poor stitching or an
incorrect assembly path. Record both component-level checks and
finished-product verification.
Common documentation gaps
- A product photo without a controlled drawing or revision.
- A “stainless steel” description without a grade or supplier
record. - A salt-spray claim without the method, duration and acceptance
criteria. - A load-test value without fixture, loading direction or sample
count. - A finish name such as “black” without an approved physical colour
sample. - No link between the incoming component batch and the
finished-product batch.
How OEM buyers can
prepare a better RFQ
Send the intended use, webbing width, product drawings, expected user
group, target markets, finish, environment and buyer-defined tests. Ask
the component supplier to confirm what data can be included in the
finished-product technical file.
Jinxing Hardware can provide controlled product information agreed
for the order, including dimensions, material, finish, sample approval
and inspection requirements. The finished product manufacturer, importer
and EU responsible person should determine the final GPSR scope and
documentation.
Frequently asked questions
Does GPSR apply only to products made in the
EU?
No. It applies to covered consumer products placed on the EU market,
including imported products.
How long must manufacturers keep GPSR technical
documentation?
Article 9 states that manufacturers must keep it available for 10 years
after the product is placed on the market.
Is a supplier test report enough for the finished
product?
Usually not by itself. The manufacturer must assess the finished
product, its intended use, foreseeable misuse and the interaction
between components.
Sources
- European Commission Access2Markets, “EU’s General Product Safety
Regulation”: https://trade.ec.europa.eu/access-to-markets/en/news/eus-general-product-safety-regulation-gpsr-new-era-consumer-protection - Regulation (EU) 2023/988: https://eur-lex.europa.eu/eli/reg/2023/988/oj/eng
This article provides general information and is not legal
advice.
