If you sell digital products, you might assume that new EU product laws don’t apply to you. After all, you’re not shipping candles or kettles, just downloads, right?
But, under the EU’s new General Product Safety Regulation (GPSR), certain digital offers do count as products.
And if that includes anything you sell, you could be legally required to appoint an EU representative.
Let’s get into it.
So… what actually counts as a product?
The new regulation applies to any item sold to EU consumers, and that includes software or anything that includes software.
So if you sell:
- Customisable templates (with logic or interactive fields)
- Notion dashboards
- Google Sheets calculators
- Downloadables with triggers, scripts, or app integrations
- Self-paced, instant access courses
…then yes, it might fall under GPSR.
It doesn’t have to be “techy,” it just has to function like a product. If your customer downloads it and uses it, it could be regulated.
Where Internal Compliance Gaps Usually Happen
Here are a few real-life ways we’ve seen compliance issues crop up unintentionally:
- A VA edits a checkout page but forgets to include terms and conditions
- Marketing Support updates automations but skips the email that contains key delivery info
- A project manager changes the contents of a digital product but does not update the risk assessment
Individually, they seem small. But under GPSR, any missed step that impacts product access, safety, or communication can become a compliance issue.
“But I’m not selling anything physical…”
If what you’re selling:
- Does something
- Guides or calculates something
- Has embedded logic
- Or might carry a disclaimer or usage note…
Then it’s worth checking if it’s classed as a product, especially if you’re selling into the EU.
This is where a lot of online business owners get caught off guard.
What does GPSR actually require?
If your digital product meets the threshold, you’ll need to:
- Appoint an EU-based “Responsible Person” (if you’re outside the EU)
- Keep basic documentation about how your product works
- Respond to any product safety issues or requests from EU regulators
This is not something that’s over-complicated and scary, you just need to be ready, and having the right setup gives you peace of mind and keeps you legally covered.
Not sure if your product qualifies?
You’re not expected to figure this out alone, and honestly, most templates and tools floating around online won’t give you a clear answer.
That’s why I offer a GPSR Appointed Person service, for online businesses like yours.
Whether you’re selling downloads, templates, or digital tools with interactive features, I’ll act as your official EU rep, keep the required documentation on file, and handle any communication from EU authorities if it comes up.
👉 Click here to get clarity for FREE about your digital products
