GPSR Penalties Matrix: EU Member State Sanctions Compared

GPSR Penalties Matrix: EU Member State Sanctions Compared – Whitepaper Overview:

The EU’s General Product Safety Regulation (GPSR) (EU) 2023/988 entered into force on 13 December 2024. As the GPSR doesn’t set specific penalty amounts for breaches of its obligations, Member States must lay down their own sanctioning regimes – bound only by a requirement that penalties be effective, proportionate, and dissuasive.

The result is an uneven enforcement landscape.

A company operating across the EU could, in principle, face simultaneous enforcement action in several jurisdictions for the same conduct, with very different financial and legal consequences in each. Adherent has built a comparative matrix bringing together the penalties applicable in 25 EU Member States*, helping businesses answer questions such as:

• Which jurisdictions impose criminal liability?
• Which can impose turnover-based fines?
• Where are documentation defects most aggressively sanctioned?

*Greece and Romania are excluded, as applicable penalties could not be conclusively verified – this doesn’t imply no penalties exist.

This Whitepaper Covers:

• A comparative penalties matrix organized around four core GPSR obligations: general safety requirements (Article 5, Article 9(1)), internal risk analysis and technical documentation (Article 9(2)), instructions and safety information (Article 9(7)), and accident reporting (Article 20)
• Administrative fine ranges by Member State, from fixed caps (e.g. EUR 25,000 in Austria) to tiered, severity-based systems (e.g. Hungary, Spain, Portugal)
• Criminal liability provisions, including imprisonment terms – up to 5 years in France for failure to take corrective action, and up to 2–4 years in Denmark, Ireland, Cyprus, and Malta for other offences
• Turnover-based fines, where penalties are calculated as a percentage of annual revenue (e.g. up to 10% in Sweden, 6% in Belgium)
• Language requirements and aggravating factors that vary by jurisdiction, plus references to the underlying national laws, acts, or decrees
• Key observations on enforcement intensity, jurisdictional overlap, and the practical EU-wide consequences of a non-compliant product regardless of where it’s first sanctioned

*This whitepaper was originally published on 7th August, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.