GPSR: What Actually Has to Appear on a Product Page

by Luca Cavallini Technical guides
GPSR: What Actually Has to Appear on a Product Page

GPSR does not ask for a badge, it asks for specific, checkable data

Regulation (EU) 2023/988 on general product safety has applied since December 13, 2024 to any non-food product sold to an EU consumer, online sales included, and that covers a store based outside the EU too, if the product reaches an EU consumer. It does not ask for a badge or a generic compliance statement: it asks for specific information to be present, in a language the consumer understands, at the point where the consumer decides to buy, meaning on the product page itself, not only in a document tucked away at the bottom of the site.

The four types of economic operator (and why the distinction matters)

The most common mistake is treating "who stands behind this product" as a single field to fill in with a name and an address. The regulation distinguishes four roles, and a single product can have more than one economic operator attached at the same time:

  • Manufacturer. Whoever makes the product, or has it designed or manufactured and sells it under their own name or trademark. They are the primary party responsible for the product's safety.
  • Authorised representative. Required when the manufacturer has no establishment in the EU: an EU-based party the manufacturer appoints in writing to act on their behalf toward the authorities.
  • Importer. Whoever first places a product from a third country on the EU market. They have to verify the manufacturer met their obligations and that the product carries the required information before placing it on the market at all.
  • Distributor. Anyone in the supply chain, other than the manufacturer and importer, who makes the product available on the market: in online retail this is often the store's own role, when it sells someone else's product without being its manufacturer or direct importer.

A store selling multiple brands, some European and some not, ends up with different combinations for different products in the same catalog: distributor only for one line, importer for another, if it is the one bringing the goods in from outside the EU.

The data that has to appear, field by field

Stripped of the legal phrasing, the data the regulation asks to be made visible to the consumer before purchase is this:

  • The manufacturer's name (or registered trade name/trademark), with a postal address and a reachable electronic contact address.
  • If the manufacturer is not established in the EU, the same data for the authorised representative or the importer, meaning the EU-based party that takes on responsibility toward the market surveillance authorities.
  • Information that identifies the product: type, batch or serial number, or another equivalent element, whenever the product itself does not already carry it legibly on the packaging.
  • Safety warnings and instructions for use, in a language the consumer in the destination country actually understands, not generically in English: a safety warning written in a language the buyer cannot read does not meet the requirement, the same principle already covered for cookie consent, applied here to physical safety instead of privacy.
  • Hazard pictograms where relevant (for example CLP/GHS ones for chemical products, or equivalents for other risk categories), when applicable to the product.
  • Conformity documentation tied to the product, when the product category requires it (declarations, certificates, technical data sheets).

This is not a loose interpretation: it is the list of fields any system built for compliance needs to be able to manage per product, because every one of these can change from one item to the next in the same catalog, even within the same product category.

The detail almost no generic guide explains: default values only go so far

A store with a few thousand products cannot fill in every page by hand, and it is entirely reasonable to have a default manufacturer or authorised representative applied to many products at once. The practical limit of this approach is that a default value can correctly cover the manufacturer or responsible party's name, which is often genuinely the same across a whole range, but it cannot cover safety warnings and usage instructions in bulk, since by nature those are specific to a single product: a generic warning good enough for the whole catalog is not, in practice, a real safety warning, it is a placeholder text that does not answer the question the regulation is actually asking ("what are the risks of *this* product"). Bulk assignment works fine for the who (the economic operator), never for the what (warnings and instructions), which stay a per-product, per-language field.

What happens when only one piece is missing, not everything

A common mistake is thinking of GPSR as a binary condition: a store is either "compliant" or it is not. In practice, checks and complaints almost always concern a single missing piece of data on a single product, for example a missing contact address for a non-EU manufacturer, or a safety warning left in the manufacturer's original language instead of being translated. This is why the distinction between the four types of economic operator matters more than it looks: a store that correctly filled in "manufacturer" for a product that actually comes from a non-EU supplier with no European authorised representative still has a gap, because the exact party the regulation wants reachable in Europe is missing.

In short

GPSR does not ask for a generic compliance sentence at the bottom of the site: it asks, page by page, who stands behind the product (distinguishing manufacturer, authorised representative, importer and distributor), how to reach them, what identifies that specific product, and warnings/instructions readable in the buyer's language. Default values help with the economic operator but they do not replace a safety warning written for the actual product. For a store managing a large catalog, a dedicated module such as cll_gpsr is one way to keep these fields organized product by product, but the list above holds regardless of how it gets managed.

GPSR Product Safety - Regulation (EU) 2023/988GPSR information on the product page: EU economic operators, per-product responsible person, safety warnings…€49.99View product

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