GPSR risk assessment example: Resin night light with coin-cell batteries

⚠ Red flags found for this product

• COIN CELLS IN A NURSERY PRODUCT: CR2032 lithium coin cells cause severe, potentially fatal internal burns within about 2 hours if swallowed. Marketing to nurseries means babies and toddlers are foreseeably exposed. Before selling, the battery compartment must be tool-only, captive-screw, drop-resistant and impossible for a child to open. Strong battery warnings are needed on the product, packaging, instructions and listing. If the compartment cannot be made robust, redesign or stop marketing the product for nurseries.
• CHILD-APPEALING LUMINAIRE: A moon night light marketed for nurseries is a portable child-appealing luminaire. Safety expectations follow EN 60598-2-10, which sets strict requirements on accessibility of batteries and small parts, stability and drop resistance.
• POSSIBLE TOY CLASSIFICATION: If the design, marketing (e.g. 'for kids to hold', 'cuddle light', play photos) or the stated use by children aged 3+ suggests play value, authorities in DE/FR/IE may classify it as a toy. That would mean the Toy Safety Directive 2009/48/EC (being replaced by the new Toy Safety Regulation), EN 71 testing, EC declaration of conformity and CE marking. To avoid this, present and photograph it strictly as a decorative light placed by adults, not as something for children to handle.
• AGE INCONSISTENCY: The seller states users aged 3+, but nurseries contain babies under 3. Do not advertise it for cots or for children to hold. Instruct adults to place it out of reach of children under 3.
• MANUFACTURER IN THE UK: The manufacturer is outside the EU, so an EU-established responsible economic operator (Art. 4 Market Surveillance Regulation / Art. 16 GPSR) is needed before selling to DE, FR and IE. Their details must appear on the product, packaging, parcel or accompanying document, and in the Etsy listing.
• ELECTRICAL & ELECTRONIC EQUIPMENT: Even at battery voltage, the product is EEE. This means RoHS applies, and WEEE producer registration is needed in DE (stiftung ear, via an authorised representative), FR and IE. Battery Regulation obligations (labelling and producer EPR registration per country) also apply. Etsy and other marketplaces may ask for registration numbers.
• LANGUAGE REQUIREMENT: Safety information must be in German for DE and French for FR. English alone is only sufficient for IE.