GPSR 2024 Regulation: What Cannabis Accessories Retailers Must Change Now

# GPSR 2024 Regulation: What Cannabis Accessories Retailers Must Change Now

As of: May 2026 — 15 months after the transition period expired, the first wave of cease-and-desist letters is underway.

Since December 13, 2024, the EU General Product Safety Regulation (GPSR, Regulation EU 2023/988) has been mandatory. No more transition period, no opt-out. It affects anyone selling vaporizers, grinders, rolling papers, bongs, chargers, or batteries through an online store — whether their own shop, Amazon EU, eBay, or Shopify.

What still seemed like a distant regulatory exercise in 2024 is now being enforced. The Association for Social Competition (VSW) is systematically reviewing cases. The ProdSG amendment from February 2026 threatens fines of up to €100,000. And the first cease-and-desist letters against smaller head shops have been documented.

I am applying the GPSR here specifically to cannabis accessories — not generic legal advice, but a sector-specific classification with current data, real-world examples, and an actionable checklist.

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The GPSR in 60 Seconds — What's New?

From GPSD to GPSR: The Most Important Differences

The old directive 2001/95/EC (GPSD) was a directive — each EU country implemented it differently. The GPSR is a regulation that is uniformly applicable in all member states from day one and does not need to be transposed into national law.

| Area | GPSD (Old) | GPSR (New) | |---|---|---| | Legal form | Directive, nationally different | Regulation, uniform across EU | | Online sales | Barely regulated | Explicit obligations for online shops | | EU representative | Not required | Mandatory for importers from third countries | | Traceability | Manufacturer information sufficient | Product identifier + manufacturer + possibly EU authorized representative | | Sanctions | Member states inconsistent | ProdSG amendment 2026: up to €100,000 |

Source: EU Regulation (EU) 2023/988, Articles 1-4; European Commission, GPSR Application Guidelines, November 21, 2025

Since When Does It Apply?

The GPSR has been in effect since December 13, 2024. There is no longer a transition period. Products placed on the market before this date are still subject to the old GPSD under Article 51 of the GPSR — but only if they were already with the end consumer. Newly stored goods must be compliant.

Current Warning: Wave of Cease-and-Desist Letters

Since spring 2025, law firms have documented a rising number of GPSR-based cease-and-desist letters in German e-commerce. The Händlerbund counted at least twelve cases in May 2025 alone. The ProdSG amendment of February 19, 2026 (§ 28 (2) ProdSG) drastically tightens sanctions: fines of up to €100,000 are now possible — not just cease-and-desist costs.

Particularly affected: retailers without an EU representative and with incomplete product pages. Source: Windweiss Rechtsanwälte, GPSR Cease-and-Desist Wave, updated April 2026.

EU Guidelines November 2025 — What Has Been Clarified?

On November 21, 2025, the European Commission published long-awaited application guidelines on the GPSR. Key clarifications:

Source: European Commission, Commission Notice on the application of the GPSR, C/2025/7890, November 21, 2025

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Which Cannabis Accessories Fall Under the GPSR?

The GPSR applies to all non-food products. This covers almost the entire range of cannabis accessories. The specific obligations vary by product group.

Category 1: Electrical Devices (Vaporizers, Chargers, Batteries)

Vaporizers and their chargers are subject, in addition to the GPSR, to the Low Voltage Directive (2014/35/EU) and, for batteries, the Battery Regulation (EU 2023/1542). CE marking is mandatory. Lithium-ion batteries in vaporizers fall into the highest risk class — the Safety Gate Report 2025 alone recorded 125 fire incidents due to electrical devices.

What retailers need: CE Declaration of Conformity, EU representative, battery safety data sheet.

Category 2: Metal Grinding Tools (Grinders)

Grinders are mechanical tools. They do not require CE marking under EU directives — but the GPSR still requires a risk assessment (Art. 9 GPSR). Special attention: magnet safety (small parts that can be swallowed) and material durability (metal abrasion). The GPSR requires the manufacturer's name and a contact address on the product or packaging.

Category 3: Glass and Ceramic Products (Bongs, Pipes)

Break resistance, sharp edges after breakage, material resistance to hot ash — these are the GPSR-relevant risks. Glass bongs from China without manufacturer information are a classic gateway for cease-and-desist letters.

Category 4: Plastic and Paper Products (Rolling Papers, Filters, Trays)

Here, the REACH Regulation (EC 1907/2006) for chemical substances also applies. Paper products must prove they do not contain harmful optical brighteners or adhesives. The GPSR requires: product identifier, manufacturer, possibly EU authorized representative, warnings in the language of the target country.

Category 5: Products Containing Batteries

The Battery Regulation (EU 2023/1542) overlaps here with the GPSR. From August 2026, new labeling requirements from the PPWR (EU 2025/40) for packaging will also apply.

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The Three Obligations That Affect Every Online Shop

Obligation 1: Product Page Content (Art. 19 GPSR)

Every product page must include:

This information must be directly visible on the product page — a link to a PDF is not sufficient. Source: European Commission, GPSR Guidelines November 2025, Section 4.2.

Practical challenge: With more than 200 products in the range, this can take weeks. Those without an ERP system with product data management prioritize: first the products with the highest risk (vaporizers, batteries), then the rest.

Obligation 2: EU-Based Economic Operator (Art. 16 GPSR)

Importing from China, the US, or the UK? Then you need an EU-authorized economic operator (Authorized Representative). This person or company is based in the EU and is liable for product safety.

Real-world example: Dynavap, a US-based manufacturer of vaporizers, has set up its own GPSR page and explicitly names an EU representative (EC REP) there. Every European retailer carrying Dynavap products can rely on this.

If the EU representative is missing, the retailer is liable themselves — and that is the risk that cease-and-desist senders actively look for.

Obligation 3: Recall and Incident Management (Safety Gate)

The GPSR obligates retailers to report product recalls and safety incidents via the Safety Business Gateway (Articles 20 and 25 GPSR). The old RAPEX system has been replaced by Safety Gate.

In practice, this means: You need a documented recall workflow that can be activated within 72 hours. Reporting deadlines for serious risks: immediately, maximum 2 working days.

Source: European Commission, Safety Gate Annual Report 2025, March 2026.

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Real-World Examples from the Industry (2025/2026)

Dynavap — Vaporizer Manufacturer with Its Own GPSR Page

Dynavap, a US manufacturer of manual vaporizers, was one of the first manufacturers in the industry to launch a dedicated GPSR compliance page. It contains:

**Takeaway for