How to Do a GPSR Product Risk Assessment

You've got 500 toy cars in your warehouse, imported from Shenzhen. You want to list them on Allegro, but in the GPSR documentation form you hit the field "risk assessment" and have no idea what to put there. The supplier sent only a certificate you can't verify. This is the most common sticking point when implementing the GPSR (EU) 2023/988 regulation: sellers understand they have to "prove safety", but don't know how to do it on paper. The good news: risk assessment is a logical process you can work through step by step — no lab, no lawyer required.

Why GPSR requires a risk assessment

The General Product Safety Regulation requires that only safe products be placed on the market. Risk assessment is the tool you use to prove that you've thought through what could go wrong, and that you've reduced the hazards to an acceptable level. It's a mandatory part of the technical documentation — without it, the file is incomplete, and the surveillance authority (in Poland, UOKiK) can challenge the product.

A risk assessment doesn't need to be a hundred-page report. For a simple product, a few pages of solid analysis is enough. What matters is that it's specific and relates to your product, rather than being a generic "cheat sheet" copied from the internet.

Step 1: Describe the product and its user

Start with a precise description: what it is, what it's made of, how it works, who will use it and how. For a toy car: "Toy made of plastic, with wheels and small parts, intended for children over 3 years old." The user group is crucial — a product intended for adults carries different risks than one for young children. Also consider "foreseeable misuse" (e.g. a child putting a part in their mouth).

Step 2: Identify the hazards

Go through the product piece by piece and list what could pose a risk to the user. Typical hazard categories include:

• Mechanical — sharp edges, small parts posing a choking hazard, parts that can come loose.
• Electrical — electric shock, overheating, faulty power supply.
• Chemical — harmful substances in the plastic, paints, phthalates.
• Thermal and fire-related — heating up, risk of ignition.
• Related to use — lack of warnings, misleading instructions.

Step 3: Assess likelihood and severity

For each hazard, estimate how likely it is to occur and how severe the consequence would be. A simple model is a scoring matrix: low/medium/high likelihood multiplied by minor/serious/critical severity. The product gives you the risk level.

Risk level	What it means	Action
Low	Unlikely or minor consequence	Acceptable, monitor
Medium	Possible event with a noticeable consequence	Introduce mitigating measures
High	Likely, or serious consequence	Action required, possibly a product change

Step 4: Introduce risk-reduction measures

For each significant hazard, describe how you're reducing it. The order matters — first elimination through design, then safeguards, and only at the end, warnings:

1. Design changes — rounded edges, no small parts, safe materials.
2. Safeguards — insulation, fuses, fastenings for parts.
3. Information — warnings and instructions for use in the language of the country of sale.

A warning alone doesn't "fix" a product that is inherently dangerous — it's the last line of defence, not the first.

Step 5: Reference the standards

If harmonised standards exist for your product category (e.g. for toys), applying them gives a presumption of conformity with the safety requirements. In the risk assessment, state which standards you've taken into account. We describe how to do this in practice in the article on harmonised standards and GPSR. Referencing a standard significantly strengthens your documentation.

Step 6: Document and keep it

Write up the risk assessment as a table or report and attach it to the technical documentation. It must be kept for 10 years from the product being placed on the market — more on this in the article on archiving documentation for 10 years. If you change the product, or a new hazard emerges, the assessment needs to be updated.

Frequently asked questions

Do I have to send the product to a lab to do a risk assessment?

Not always. For simple products, a solid analysis based on knowledge of the product and the relevant standards is enough. Laboratory testing can be needed for chemical or electrical hazards, or for toys — in which case a test report strengthens the documentation.

How detailed does the risk assessment need to be?

Proportionate to the product. A simple gadget needs a few pages; an electrical product for children needs a lot more. The rule: the greater the potential hazard, the more thorough the analysis.

What if the assessment shows a high risk that can't be removed?

If, after applying all the measures, the risk remains high, the product must not be placed on the market. The risk assessment acts as a filter here — its purpose is to catch such cases before the product goes on sale.

Who signs off the risk assessment?

Responsibility lies with the entity placing the product on the market — the manufacturer or importer. As the seller-importer, you take responsibility for its reliability, even if you're relying on material from your supplier.