EU Compliance & Market Access
Product & Market Access
What EU law requires before a product can be placed on the market — safety, official controls, and material restrictions.
Regulation (EU) 2023/988
General Product Safety Regulation (GPSR)
Replaced the 2001 General Product Safety Directive. Extends safety obligations to online marketplaces and introduces mandatory digital traceability for all consumer products placed on the EU market.
- In force
- 13 December 2024
- Scope
- All consumer products placed on the EU market — including pet accessories, toys, leads, beds, and any product not covered by sector-specific legislation
- Online marketplaces
- Must ensure products listed are safe; bear direct obligations under this regulation, not just host liability
- Economic operators
- Must register products in the EU Safety Gate portal; maintain technical documentation
- Incident reporting
- Mandatory notification to authorities within 2 working days of identifying a serious risk
- Enforcement body
- National market surveillance authorities (coordinated via RAPEX / Safety Gate)
- Replaces
- General Product Safety Directive 2001/95/EC
Suppliers exporting to the EU must ensure their EU importer or authorised representative can demonstrate compliance. Products sold via platforms (Amazon, Zalando, etc.) fall within marketplace obligations.
Regulation (EC) 178/2002 + Regulation (EC) 767/2009
Food, Feed & Animal-Product Controls
178/2002 (General Food Law) establishes the legal framework and traceability obligations for all food and feed. 767/2009 governs the specific requirements for placing pet food on the EU market.
- 178/2002 — key bodies
- Establishes EFSA (European Food Safety Authority) and RASFF (Rapid Alert System for Food and Feed)
- 178/2002 — traceability
- Farm-to-fork traceability mandatory; operators must identify suppliers and immediate customers (one step back, one step forward)
- 767/2009 — labelling
- Pet food labels must state: species suitability, nutritional adequacy statement, ingredient list in descending order by weight, analytical constituents
- 767/2009 — operators
- Feed business operators (FBOs) must be registered with the national competent authority before placing pet food on the market
- Contaminant limits
- Set under Regulation (EC) 574/2011 and Directive 2002/32/EC — covers heavy metals, mycotoxins, dioxins, pesticide residues
- Enforcement body
- National competent authorities; EFSA provides scientific opinions; Commission coordinates through DG SANTE
Thailand-origin pet food ingredients (fish meal, poultry by-products) are subject to import conditions. Check current third-country approval status and any RASFF alerts for the relevant product category before sourcing.
Regulation (EC) 1907/2006 + Directive 2011/65/EU
Chemicals & Restricted Substances — REACH & RoHS
REACH governs the registration, evaluation, and restriction of chemical substances in products. RoHS restricts hazardous substances in electrical and electronic equipment. Both are directly relevant to pet accessories and smart devices.
- REACH — importers
- EU importers are classified as downstream users and bear registration and notification obligations for substances in articles
- SVHC threshold
- Articles containing >0.1% w/w of any Substances of Very High Concern (SVHC) require notification to ECHA and disclosure to customers within 45 days of request
- SVHC Candidate List
- 240+ substances currently listed; updated twice yearly by ECHA — includes certain phthalates, lead compounds, bisphenols
- RoHS — scope
- Electrical and electronic equipment placed on EU market — applies to electronic pet feeders, GPS trackers, heated beds, smart collars
- RoHS — restricted substances
- 10 substances restricted, including lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, DIBP
- RoHS — limits
- Maximum concentration 0.1% by weight of homogeneous material (0.01% for cadmium)
- Enforcement body
- ECHA (REACH); national market surveillance authorities (RoHS)
REACH SVHC compliance requires active supply chain communication. Suppliers should provide a declaration of SVHC content as part of standard onboarding documentation. The Candidate List changes frequently — static declarations become stale.
Regulation (EC) 1935/2004 + Regulation (EU) 10/2011
Food-Contact Materials (FCM)
Sets safety requirements for all materials and articles that come into contact with food or pet food — including packaging, bowls, scoops, and storage containers.
- Scope
- All materials intended to contact food or pet food: plastic, metal, ceramic, rubber, paper, board, silicone — applies at manufacturing, retail, and consumer stage
- Core obligation
- Materials must not transfer components to food in quantities that could endanger human or animal health, or cause unacceptable changes in the composition or organoleptic properties of the food
- Declaration of Compliance
- Suppliers of FCMs must provide a DoC to their customers at each stage of the supply chain; DoC must reference applicable legislation and substance migration limits
- Regulation (EU) 10/2011
- Specific measures for plastic materials in contact with food — Union List of authorised monomers and additives; overall migration limit 10 mg/dm²; specific migration limits per substance
- Testing
- Migration testing required under EN 1186 (plastics) and equivalent standards; test conditions must reflect actual conditions of use
- Enforcement body
- National food safety authorities (e.g. EFSA, BfR in Germany, ANSES in France)
Pet food bowls and storage containers sold in the EU must be accompanied by a valid DoC from the manufacturer. Importers sourcing these from Southeast Asia should request DoC documentation and confirm testing was conducted against EU migration limits, not only local standards.