GPSR risk assessment example: Beaded charm bracelet (zinc-alloy charm)

⚠ Red flags found for this product

• The manufacturer is in the United Kingdom, which is outside the EU. Under GPSR Art. 16 you must not sell to DE, FR or IE consumers unless an economic operator established in the EU (authorised representative, importer or fulfilment service provider) is designated. Its name, postal address and email must appear on the product, packaging, parcel or accompanying document, and in the Etsy listing.
• Zinc-alloy charms from low-cost supply chains are a frequent subject of EU Safety Gate alerts for lead and cadmium. A verbal 'nickel-free' statement from the supplier is not evidence. You need a written test report covering nickel release, lead and cadmium, or you must test the charm (and any jump ring) before selling. Without it, do not claim 'nickel-free' in the listing.
• Toy borderline: 'charm bracelets' are popular with children. If the listing, photos, colours or keywords ('for girls', 'kids', cartoon motifs, 'party bag') target children under 14, authorities may classify it as a toy. That would bring in the Toy Safety Directive 2009/48/EC (EN 71 testing, CE marking, EU declaration of conformity). Keep the presentation clearly aimed at teens and adults.
• The 6 mm beads and the charm fit within the small-parts cylinder. If the cord breaks, they are a choking and aspiration hazard for children under 3. This must be controlled through cord and knot quality, and through warnings on the packaging and in the listing.
• Language requirements apply: safety information must be in German for DE, French for FR, and English for IE. An English-only leaflet is not sufficient for DE and FR customers.