GPSR Lawyer in the Netherlands: Martin Krüger

Published on 13 November 2026

A GPSR lawyer in the Netherlands helps manufacturers, importers, distributors and online platforms with the General Product Safety Regulation (Regulation (EU) 2023/988). I am Martin Krüger, a Dutch product law attorney and managing partner at MAAK Advocaten in Amsterdam. I specialise in the GPSR and advise companies on their obligations and on market surveillance.

Who needs legal advice on the GPSR in the Netherlands?

The GPSR covers consumer products made available in the EU, including offers from outside the EU that target consumers in a Member State (Articles 3(1) and 4 GPSR). Whether you need a lawyer depends on your role and on what has gone wrong.

The GPSR has applied since 13 December 2024 and replaced Directive 2001/95/EC (Articles 52 and 50(1)). Typical situations are a manufacturer outside the EU selling to Dutch buyers, an EU manufacturer with a Dutch distributor, an importer asked for an indemnity, or an online seller whose marketplace wants a named responsible person.

For the rules themselves, read our guide to the General Product Safety Regulation, our overview of EU product law and the PPWR FAQ for packaging.

Which role do you have under the GPSR?

The GPSR distinguishes the manufacturer, authorised representative, importer, distributor and fulfilment service provider (Article 3, points 8 to 12). Selling under your own name or substantially modifying a product makes you the manufacturer (Article 13).

Your own name or trademark makes you the manufacturer (Article 13(1)). So does a substantial modification, by physical or digital means (Article 13(2)). A modification is substantial when it affects the safety of the product and meets three conditions: it changes the product in a way the initial risk assessment did not foresee, it changes the hazard or raises the risk, and it was not made by or for consumers for their own use (Article 13(3)).

Important: a Dutch webshop adds its own brand to a supplier’s product, or a software update changes how a product behaves. Under Article 13 GPSR you can then be the manufacturer, with the Article 9 duties and the liability that follow. Have a Dutch product law lawyer review your role and the supplier contract before you launch the private label or push the update.

What does the GPSR ask of each role?

Manufacturers carry the heaviest duties: a risk analysis, technical documentation kept for 10 years, product identification, contact details and instructions in the language of the Member State (Article 9). Importers and distributors check that the manufacturer has done this (Articles 11 and 12).

Every operator needs internal product-safety processes and must give the authorities information and traceability data on request (Articles 14 and 15). Online offers must show the manufacturer, the responsible person where the manufacturer is outside the Union, product identification and safety warnings (Article 19). Much of this is work you can do yourself:

keep the risk analysis and technical documentation up to date;
put a type, batch or serial number and your contact details on the product, packaging or an accompanying document;
supply instructions and safety information in Dutch (Article 3 Warenwetbesluit);
as manufacturer, set up a consumer complaints channel and an internal register (Article 9(11) and (12)).

Start with one list per product of what has to be in Dutch and who supplies that text. The legal question comes next: who supplies the documentation, who answers the authority, and who pays if a product is withdrawn. Those answers sit in your contracts, and their wording decides whether you have recourse against your supplier.

Not sure which role your company has? Contact me as your Dutch product law attorney and tell me how your products reach Dutch buyers.

What is a responsible person under the GPSR, and do you need one?

A product may only be placed on the market if an EU-established operator is responsible for the Article 4(3) tasks of Regulation (EU) 2019/1020 (Article 16(1) GPSR): an EU manufacturer, importer, authorised representative or, as a last resort, a fulfilment provider.

The list is in Article 4(2) of Regulation (EU) 2019/1020. An EU manufacturer is its own responsible person; a manufacturer in the United States or Asia needs an importer, a mandated representative or a fulfilment provider. An authorised representative is optional: Article 10(1) says a manufacturer “may” appoint one.

The responsible person regularly checks the product against its technical documentation and is named on the product, packaging or an accompanying document (Article 16(2) and (3)). See also our page on the EU authorised representative. Who takes the role, and on what mandate, is a legal choice with consequences for documents, costs and liability. A lawyer can advise on that choice and on the contract around it. Access to the technical documentation is one point to settle, because an authority’s deadline does not wait for documents held abroad.

What must you report through the Safety Business Gateway?

A manufacturer that has reason to believe a product it placed on the market is dangerous must immediately take corrective measures, inform consumers and notify the authorities through the Safety Business Gateway (Article 9(8) GPSR). Accidents follow Article 20.

The Safety Business Gateway is the Commission’s web portal for these notifications (Article 27(1)). A notification gives details of the risk, the measures taken and, if available, the quantity per Member State still on the market (Article 9(8)). The manufacturer notifies an accident without undue delay to the authorities of the Member State where it happened (Article 20(1)); importers and distributors inform the manufacturer (Article 20(3)).

The hard part comes before the filing: is the product dangerous within Article 3(3), and what do you say about the risk and the measures?

Important: a Dutch customer reports an injury from your product and your distributor asks you to “handle the notification”. Under Articles 9(8) and 20 GPSR the manufacturer notifies, and importers and distributors must inform it without undue delay. Before you file in the Safety Business Gateway, or instruct someone else to, have a Dutch product law lawyer review what you say about the risk and the measures taken.

Which Dutch authority enforces the GPSR, and what can it do?

Dutch law prohibits acting contrary to the GPSR articles listed in the Warenwetbesluit (Article 2); officials designated by the minister supervise (Article 25 Warenwet). Which inspectorate acts depends on the product; in my work these are the NVWA, RDI and ILT.

The authorities use the powers of Regulation (EU) 2019/1020, which Article 23(1) GPSR makes applicable. Under Article 14(4) they can require documents and information, inspect without notice and require an operator to end non-compliance. If it does not, they can prohibit or restrict the product or order a withdrawal or recall.

Dutch law adds its own instruments: a last onder bestuursdwang (order backed by administrative enforcement, Article 32 Warenwet) and an order to take a dangerous product off the market or recall it if an operator fails to take appropriate measures, which must be followed without delay (Article 32h). You can object (bezwaar) within six weeks (Article 6:7 Awb); in general objection comes before an appeal to the administrative court (Article 7:1 Awb).

Important: a Dutch inspector asks for your technical documentation and supply-chain details, with a short deadline. Article 15(2) and (3) GPSR obliges you to provide information on request, and what you hand over can shape the decision that follows. Have a Dutch product law lawyer review the response before you send it, and note the six-week objection period (Article 6:7 Awb) as soon as a decision arrives.

What happens if a recall is needed?

If a product proves dangerous, the manufacturer must immediately take corrective measures, including withdrawal or recall, and inform consumers (Article 9(8)). Identifiable consumers are notified directly (Article 35(1)); a written notice follows Article 36(2).

The notice carries the headline “Product safety recall” and must avoid wording that lowers the perception of risk, such as “voluntary” or “precautionary” (Article 36(2)). In the Netherlands it must be in Dutch (Article 3 Warenwetbesluit). Wording and sequence of a recall are a legal and communications judgement. For the requirements, see our page on product recall obligations under the GPSR.

When do you need a GPSR lawyer?

Bring in a lawyer when an authority or customer asks for documents or a notification (Article 15 GPSR), when you are asked to take a role or give an indemnity (Article 16), or when a change may make you the manufacturer (Article 13).

Your situation	What is at stake	Why a lawyer	What a lawyer does first
An authority asks for documents or traceability data	Duty to provide information on request (Art. 15(2), (3) GPSR); powers under Art. 14(4) of Regulation 2019/1020	Your response can shape the measure that follows, and objection periods are short (Art. 6:7 Awb)	Review the request and the deadline, check the documents, prepare the response
A customer, importer or marketplace asks you to be the responsible person or to give an indemnity	Art. 16(1) GPSR with Art. 4(2) of Regulation 2019/1020; minimum mandate tasks (Art. 10(2) GPSR)	An adviser can tell you what the law requires; settling who performs the tasks and who pays is contract law	Review the contract, advise on the allocation of roles and costs
You sell under your own brand or change the product	Deemed manufacturer with the Art. 9 duties (Art. 13 GPSR)	The effect on liability and on supplier contracts is a legal question, not a technical one	Establish your role and advise on the supplier contract
A product may be dangerous, or an accident is reported	Immediate measures and notification (Art. 9(8), 20 GPSR); order to withdraw or recall (Art. 32h Warenwet)	What you notify, and when, has to rest on a legal assessment of the facts	Assess the facts, advise on notification and measures, contact the authority
An authority issues an order or a decision	Art. 32 and 32h Warenwet; objection within six weeks (Art. 6:7, 7:1 Awb)	Objection and appeal are formal procedures with fixed periods	Secure the objection period and prepare the objection

What does this look like in practice? A fictional example

This example is fictional. A US company makes travel pillows and wants to sell to Dutch consumers through an online marketplace. It has no EU entity. The marketplace asks for a responsible person’s name and address (Article 19(b) GPSR) and for an indemnity.

The company can use an importer, a mandated representative or, as a last resort, a fulfilment provider (Article 4(2) of Regulation 2019/1020). The role, the contract and the indemnity need to be reviewed together, and the Dutch instructions and documentation checked before the listing goes live.

How do I work on GPSR matters?

I advise and litigate for manufacturers, importers, distributors and online platforms, and I represent companies in enforcement by the NVWA, RDI and ILT.

A GPSR matter starts with your documents, your deadline and the contracts in your chain. I work with the contract law and litigation specialists at MAAK Advocaten, so compliance, contracts and proceedings stay consistent. Where an authority issues a decision, I can file the objection and, if needed, litigate before the administrative court. I advise in Dutch, German and English.

For product regulation combined with supply contracts, my colleague Félique Kouthoofd, a product regulation attorney in the Product Law team, is also available.

Frequently asked questions about the GPSR and Dutch enforcement

Does the GPSR apply if I sell online from outside the EU to buyers in the Netherlands?

Yes, if your offer targets consumers in the Union: online offers count as made available when the operator directs its activities to one or more Member States (Article 4 GPSR). The offer must then show the responsible person (Article 19(b)).

Do I need an EU authorised representative to sell consumer products in the Netherlands?

You need an EU-established economic operator who is responsible for the Article 4(3) tasks (Article 16(1) GPSR). That can be an importer, an authorised representative or a fulfilment service provider. An authorised representative is optional: a manufacturer “may” appoint one (Article 10(1)).

Which product information must be in Dutch?

Instructions, warnings, safety information and recall notices must in any case be in Dutch (Article 3 Warenwetbesluit). The GPSR requires instructions and safety information in a language consumers can easily understand, as determined by the Member State (Article 9(7)).

Who notifies a dangerous product or an accident?

The manufacturer notifies a dangerous product through the Safety Business Gateway (Article 9(8) GPSR) and accidents to the Member State where they happened (Article 20(1)). Importers and distributors inform the manufacturer; for a manufacturer outside the Union, the responsible person ensures notification (Article 20(4)).

What can Dutch authorities order if I do not act?

They can require you to end non-compliance and, if you do not, prohibit or restrict the product or order a withdrawal or recall (Article 14(4) of Regulation 2019/1020). The minister can also impose an order to withdraw or recall a dangerous product (Article 32h Warenwet).

When should I contact a GPSR lawyer in the Netherlands?

Contact a lawyer before you accept a role or an indemnity, before you answer an authority, and as soon as a product may be dangerous. At MAAK Advocaten we then review your role, documents and contracts, because the answer depends on your facts.