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What Is a “Jewellery Product Type” Under the EU GPSR?
What Is a “Jewellery Product Type” Under the EU GPSR?
EU General Product Safety Regulation
The EU General Product Safety Regulation (Regulation (EU) 2023/988), the way a “product type” (or “item”) is defined determines what documentation, risk assessments, and labelling are required for compliance.
This is a practical explanation tailored to jewellery businesses. It is consistent with how EU market surveillance authorities and recognised GPSR representatives (e.g., Obelis, CE Partner, SGS, ProductIP) interpret the term.
What Is a “Jewellery Product Type” Under the EU GPSR?
1. Core Definition
A product type in the context of the GPSR means:
Each product type must be evaluated individually for safety and compliance, because differences in design, materials, or intended use can create different risk profiles under EU law.
2. How to Determine a Distinct Product Type
You should treat a jewellery product as a separate “product type” when any of the following change:
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Category
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Examples of Change That Create a New Product Type |
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Design / Shape
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A new ring design, pendant shape, or clasp mechanism |
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Material Composition
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Gold vs silver vs plated brass, change in coating or alloy |
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Functional Feature
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Magnetic closure, adjustable ring, innovative/connected jewellery |
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Size Variation with Different Construction
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Large cuff vs small bangle if design or material thickness differs |
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Target User / Intended Age Group
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Children’s vs adult jewellery |
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Surface Treatment or Finish
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Nickel-plated vs nickel-free, lacquer coating, or anodised finish |
If the product’s safety testing, labelling, or user group differs, it’s treated as a separate product type.
3. Examples for Jewellery
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Jewellery Category |
Distinct Product Types (Examples) |
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Rings |
“Silver plain ring”, “Gold ring with gemstone”, “Adjustable brass ring”, 3 product types |
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Bracelets |
“Leather bracelet with metal charm”, “Magnetic health bracelet”, different product types due to materials and magnetism |
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Necklaces |
“Gold chain”, “Pendant necklace with clasp”, “Children’s plastic bead necklace”, 3 product types, different risk and audience |
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Earrings |
“Stud earrings (silver)”, “Hoop earrings (plated metal)”, separate due to material and construction |
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Cufflinks |
“Steel cufflink with resin inlay”, “Silver cufflink”, separate SKUs, separate documentation |
Each unique SKU (Stock Keeping Unit) typically corresponds to a distinct product type in the compliance documentation.
4. Why This Matters for GPSR
The GPSR requires that each product type have:
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A technical file (including description, materials, and conformity evidence)
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A risk assessment based on foreseeable use and materials
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Labelling and traceability specific to that model
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Clear documentation that allows authorities to identify and trace each product variant
Even if two designs look similar, if they differ in material, coating, or intended user (e.g., adult vs. child), they may pose different risks (e.g., nickel release, small parts choking hazard). Thus, they must be treated as separate product types.
5. Summary
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Aspect |
Definition Under GPSR for Jewellery |
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Product Type |
A distinct design or SKU with unique material or functional characteristics |
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Purpose |
To allow proper risk evaluation and product traceability |
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Documentation |
Each product type requires its own safety file and declaration |
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Typical Trigger for New Type |
Material change, design change, or new intended user group |
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Example |
A silver ring and a gold ring are two product types, even if they share the same shape |
6. Common Mistakes to Avoid
Many jewellery brands mistakenly register a whole category (e.g., “bracelets”) as a single item under GPSR.
This is non-compliant because:
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Each variation could have different chemical, physical, or mechanical risks.
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The EU Representative cannot verify conformity for all variations under one entry.
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Authorities may treat this as incomplete or misleading documentation during inspection.
7. Practical Tip
To simplify compliance:
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Group products only when materials, construction, and risks are identical.
Use one master technical file for a base design and attach variant appendices (e.g., “same design in 3 colours”). -
Each SKU or type listed under your IXXO EU Representative agreement should match one product type record in your documentation.
10/2025 IXXO Compliance Department
