The official guidance states that the regulation only applies to ‘products placed on the market from 13th December 2024’. However, there is confusion about what ‘on the market’ means. Some people are advising that if something has been made before 13th December, it is exempt, but others are advising that ‘on the market’ means the product has to be physically inside the EU.
The reality is that from 13th December, you need to have an EU Responsible Person to ship products to the EU, and even if you think your products are exempt, it is advised to have your shipments and listings GPSR compliant and clearly labelled. This has been confirmed by my EU Responsible Person and the UK Export Academy at the UK Department for Business and Trade.
Practically speaking, checks are going to start occurring, and you need to make it easy for market surveillance authorities to see that you comply and not fall foul of the new regulations!