GPSR for Baby and Childcare Products

Bottles, pacifiers, prams, baby carriers, changing mats, sippy cups - baby and childcare products are among the best-selling groups on Allegro, and one of the riskiest for a seller. Parents report problems more often than other customers, and market surveillance authorities treat the category as a priority. An important point up front: most of these products are not toys, so the Toy Safety Directive and CE marking do not apply. Their basic safety regime is Regulation (EU) 2023/988 (GPSR), applicable since 13 December 2024. This article covers your duties for childcare products that are not toys. If you also sell toys, read GPSR for Toys: Additional Requirements.

Toy or childcare article? That's the first question

• Toy - a product intended for play by children under 14. The Toy Safety Directive and CE marking apply, with GPSR adding requirements such as online sales data.
• Childcare article - a product for care: feeding, carrying, sleeping, hygiene. A bottle, pacifier, pram or high chair is not a toy. No CE marking; safety is governed by GPSR together with European standards for each product group.

Watch out for combined products: a teether with a rattle may be a toy, and a pacifier with a clip has separate requirements for each element. When in doubt, assess the product's function: if it invites play, expect the toy regime.

Why this category is watched so closely

An infant won't read a warning or put down a failing product. That's why risk assessments for childcare articles assume worst-case use scenarios. The most frequently recorded hazards:

• Choking - detaching small parts: clips, pacifier handles, decorative elements,
• Strangulation - overlong cords, ribbons and pacifier chains,
• Falls and crushing - prams and high chairs with unreliable brakes, buckles or folding mechanisms,
• Chemicals in mouth contact - plasticisers and other substances in materials a child sucks or chews,
• Overheating and burns - bottle warmers, flasks, baby monitors with power adapters.

European standards: your requirements map

European standards exist for most childcare articles - pacifiers, bottles, prams, cots, carriers, high chairs - describing requirements and test methods. GPSR doesn't strictly mandate standards, but compliance with them is the simplest way to demonstrate safety. How that presumption works is explained in Harmonised Standards Under GPSR: What They Mean. In practice: before ordering, ask your supplier which standard the product was tested against and request the test report.

When assessing product safety, GPSR requires taking into account consumer groups at particular risk, above all children. A baby product must be safe not only in correct use but also in foreseeable situations: when a child chews it, pulls it, tips it over or uses it against the instructions.

Seller duties for childcare products

If you import childcare articles from outside the EU, you are the importer and responsible for the full document set:

Product group	Main risks	What to check in the documentation
Pacifiers and pacifier accessories	Choking, strangulation, chemicals	Test reports against the pacifier standard, clip length, mouth-contact materials
Bottles and sippy cups	Chemicals, mechanical damage	Food-contact material testing, temperature resistance
Prams and strollers	Falls, crushing, brakes	Test report against the pram standard, Polish instructions, harness warnings
High chairs	Falls, tip-over	Stability, safety harness, adult supervision warning
Carriers and slings	Child falling, positions restricting breathing	Illustrated fitting instructions, weight limits, warnings

Labelling and instructions: Polish is essential

• instructions and warnings must be in Polish, simple and unambiguous,
• the product or packaging carries the manufacturer's details, the EU responsible person's details and an identifier (model, batch),
• weight and age limits appear both on the product and in the listing,
• in the Allegro listing you complete the GPSR fields: manufacturer, responsible person, warnings - the technical how-to is in GPSR on Allegro: How to Add the Required Data.

What to do when a parent reports an accident

Take customer reports in this category extremely seriously. If a product caused an accident endangering health, the manufacturer (in practice often the importer acting as manufacturer) must report it to the authorities via the EU Safety Business Gateway portal. Add to that the duty to cooperate with authorities and possibly withdraw the batch. Plan the procedure in advance: customer contact, batch identification, a notice template. Details in Safety Gate, Reporting and Product Withdrawal.

Common mistakes in the children's category

• treating childcare articles as toys (or vice versa) and applying the wrong requirements,
• no test reports against the standards for the product group,
• instructions only in English or machine-translated, with errors in warnings,
• no weight and age limits in the listing,
• ignoring parents' reports that should trigger the accident reporting procedure,
• missing responsible person details on the packaging.

Frequently asked questions

Does a baby bottle carry CE marking?

No. Bottles and pacifiers are childcare articles, not toys, so the Toy Safety Directive and CE marking don't apply. Their safety is governed by GPSR, European standards and food-contact material rules.

How do I know whether my product is a toy or a childcare article?

Function decides: a product intended for play is a toy; a product for care (feeding, sleep, carrying, hygiene) is a childcare article. Products combining both functions may fall under both regimes at once.

Do I need an EU responsible person?

If the product comes from outside the EU - yes, always. Usually that's you as the importer, and your details must appear on the product or packaging and in the listing.

What are the consequences of selling a non-compliant childcare product?

The platform can hide or remove listings, and a market surveillance authority can order a withdrawal and impose administrative penalties under national law. In this category there's also liability for harm caused to a child - the most painful scenario of all.