EU GPSR for hair foil

Who GPSR covers

The General Product Safety Regulation is the EU’s general rule that consumer products must be safe. It replaced the earlier directive and applies directly in every member state. Its basic statement, with the legal reference and the date of our last check:

It reaches hair foil because of who buys it, not because of what it is made of. A box of foil on a marketplace listing that any member of the public can order is a consumer product. The same box sold by a wholesaler to hairdressers through a trade account is a professional one.

Professional vs consumer channel

The line is drawn by the channel and by what is reasonably foreseeable.

Channel	Position
Wholesaler selling to salons on trade accounts	Professional product
Brand’s own shop open to anyone	Consumer product
Online marketplace listing	Consumer product
At-home highlighting kit	Consumer product
Salon-supply shop that also sells to the public	Likely to reach consumers; treat as a consumer product

A product intended for professionals still falls under the regulation if consumers are likely to use it under reasonably foreseeable conditions. If your foil can be bought by the public, plan for the regulation to apply.

What the responsible person does

A consumer product may be placed on the EU market only if there is an economic operator established in the EU who is responsible for it. That operator:

• checks that the technical documentation exists and keeps it available for the authorities;
• gives the authorities information and documents on request;
• informs the authorities where it has reason to believe a product is dangerous;
• cooperates in corrective action, including a recall.

For a brand based outside the EU, the responsible person is usually an authorised representative appointed in writing, or the importer. A factory in China cannot fill the role.

Labelling and documents

The product, or its packaging, carries:

Item	Detail
Product identification	A type, batch or serial number, or another element that identifies the product
Manufacturer	Name, registered trade name or trade mark, postal address and electronic address
Responsible person	Name, postal address and electronic address, where the manufacturer is outside the EU
Safety information	Any warnings and instructions, in a language the member state accepts

An online listing shows the same information. Behind the label sits the technical documentation: a description of the product, an analysis of the risks and how they are dealt with, and the reports that support it.

For hair foil the realistic risks are few: cut edges, and for printed foil the behaviour of the ink in contact with lightener. The documentation should address them plainly. Where the box text goes is covered in labelling hair foil boxes.

What the factory can supply

We are the manufacturer, and our details go on the product as such. What we provide for your file:

Document	Purpose
Product specification	Describes the product: size, thickness, alloy, finish, pack
Material certificate	States the alloy and temper of the foil
Safety data sheet	Describes the material and its handling
Ink bleach test, for printed foil	Addresses the one risk specific to printed foil
Lot code on the box	Identifies the batch, for traceability and recall

The responsible person, the risk analysis and the declaration that the product is safe are yours to arrange. Hair foil for the EU market covers the duty questions that sit beside this one, and hair foil for private label brands puts both in the order a new brand meets them.