GPSR for Amazon Handmade: What the 'Exemption' Actually Covers

If you sell on Amazon Handmade, you have probably seen the line that says Handmade is "excluded" from uploading certificates. It is real. It is also the most misread sentence in the whole GPSR rollout. The exclusion is an Amazon catalog policy, not a carve-out in the law. You still owe the core of GPSR. This guide separates the two so you know exactly what to do.

The one sentence that causes all the confusion

Compliance tools that integrate with Amazon spell it out plainly. One e-commerce service describes its scope as "test reports and declarations of conformity for all products (excluding Amazon Handmade, food and medicines)." Read quickly, that sounds like Handmade sellers are off the hook. They are not.

What that line actually means: Amazon does not force Handmade sellers to upload a technical certificate, a test report, or a formal Declaration of Conformity into the catalog before a listing can go live. That is Amazon's internal moderation rule. The General Product Safety Regulation (EU 2023/988) makes no such exception. Article 2 covers consumer products across the board, and Amazon's own help pages say so: "Most non-food consumer products that are offered for sale in the EU are in scope of the GPSR, including used, repaired, and reconditioned products, handmade products, print books, and spare parts."

So the document upload is waived inside Amazon. The obligation to be safe, traceable, and contactable under EU law is not.

For the wider picture of what the regulation demands, start with [/blog/what-is-gpsr]. If you want the version written for makers outside the marketplace, see [/blog/gpsr-handmade].

What you still owe, even on Handmade

Strip away the certificate upload and four duties remain. These apply to your candles, your bunting, your leather baby shoes, your art prints.

An EU Responsible Person, if you sell from outside the EU. This is the big one for non-EU makers. Amazon's seller help is direct: "Handmade products sold in the EU are subject to GPSR. A Responsible Person can be one of the following, provided they are established in the EU or Northern Ireland." A seller in Switzerland was told the same thing on the German forum: you need a bevollmächtigte Person in der EU, and a GTIN exemption does not change that. EUProof does not provide the Responsible Person service itself, so you appoint one separately. We explain the role and your options in [/blog/gpsr-responsible-person].

Manufacturer and Responsible Person contact on the product. GPSR wants a consumer to be able to find who made the item and who is accountable for it in the EU. That means a name and address on the unit or its packaging. A QR code or an online listing alone does not satisfy this.

Safety warnings where the product carries a risk. A handmade candle is a fire hazard. A knitted toy with a long cord is a strangulation and choking risk. One Amazon seller described exactly this kind of product: leather crawling shoes, made to order, with an elastic band "länger als 25cm," longer than 25cm. A long band on a baby item is exactly the kind of feature you should weigh when you decide what to warn about. Match the warning to the real hazard.

Traceability. Keep enough records to trace a batch or an order if something goes wrong. For a maker this can be as light as a notebook or a spreadsheet, but it has to exist. Note the date you made a batch, the materials and supplier, and which orders it went into. If a wax or a dye later turns out to be a problem, that record is how you tell affected buyers apart from everyone else.

A worked example helps. Say you sell painted prints, like the Amazon seller who described having to "manually add Product Policy Compliance to all my (2700+) items." On a Handmade-style catalog you skip the certificate upload, but each print still needs your contact block on the back or the packaging, and your file should note the inks and paper you use. Volume does not change the duty. It just means you build the contact block into your template once and reuse it.

The exemption is internal. Authorities are not.

Here is the part that trips people up after they relax. Amazon waiving the upload does not waive a market surveillance authority's right to ask you directly.

A Handmade seller can still get a request from a national regulator such as France's DGCCRF for technical documentation, even though Amazon never asked for it. That is why a [/blog/gpsr-risk-assessment] is worth doing even when no one is demanding the file today. A short written assessment of your product's foreseeable risks, the materials you use, and the warnings you applied is the document you hand over if the request lands. For makers, it is usually a one-page exercise per product type, not a lab report.

If you want a structure to follow, our [/blog/gpsr-technical-documentation-template] walks through what a lightweight maker file should hold. EUProof generates that documentation so you have something on the shelf, instead of scrambling after a regulator emails you.

Customized and made-to-order items

"How do I label something I make fresh for each customer?" is the most common Handmade question, and the answer is reassuringly boring. The unit or its packaging still needs the manufacturer and Responsible Person contact details, customized or not. Use a removable sticker, or print the details on the box or tag. You do not need a new label design per customer. You need the same contact block on every item that ships.

GTIN exemption is not GPSR

Handmade sellers can apply for a GTIN exemption in Seller Central so they can list without buying barcodes. Useful, but keep it in its own box. The GTIN exemption is about catalog identifiers. It says nothing about product safety, and it removes no GPSR duty. Getting the GTIN exemption and being GPSR-ready are two separate jobs.

If you are in the UK

UK Handmade sellers shipping into the EU carry the full non-EU seller load: an EU Responsible Person, compliant labeling, and prepared safety information. The friction is real. One UK seller put it bluntly about the parallel Northern Ireland rules, saying they would "stop my items showing for sale in NI" because they could not add the required data to the listings. Plenty of small UK makers have made the same call and paused EU sales rather than take on the work. That is a valid choice, but it is a choice. If you want to keep selling into the EU, the Responsible Person and the labeling are not optional. The UK's own regime is a separate matter, covered in [/blog/gpsr-uk].

A short checklist before you list

Run through this and you have covered the parts Amazon will not check for you:

• An EU Responsible Person named and under a signed agreement (if you are non-EU).
• Manufacturer name and address plus RP contact printed or stickered on every unit.
• Safety warnings matched to your product's actual hazards.
• A one-page risk file kept on hand, even though Amazon never asks for it.
• GTIN exemption applied for if you list without barcodes.

For the full seller-facing version of this list, see [/blog/gpsr-compliance-checklist]. When you are ready to produce the underlying documents, [/templates] and our [/tools/am-i-affected] checker are the fastest way to find out what your specific products need.

The short version: Amazon Handmade saved you an upload, not a regulation. Treat the exemption as a paperwork convenience inside one marketplace, build the four real duties into how you make and ship, and you stay both listed and lawful.

This article is general guidance, not legal advice. Confirm your obligations with a qualified advisor or your Responsible Person.