EU Label Compliance

European Union

GPSR label requirements: what must be printed on a product sold in the EU

The General Product Safety Regulation applies to almost every non-food consumer product on the EU market. Most of it is about what you must be able to prove. A small, persistent part is about what must be printed on the item itself.

Example of the label this guide describes
Facsimile of the file we deliver. Sample data, fictitious company.

The four blocks that must appear

Article 9 requires the manufacturer’s name, registered trade name or trade mark, and postal address on the product, or on its packaging, or on an accompanying document. A website is not an address.

Article 9 also requires a type, batch, or serial number that identifies the product. One number for an entire catalogue does not identify anything: it must specify a particular production run.

Article 16 adds the economic operator established in the Union — the responsible person — with their own name and postal address. For goods originating outside the EU, this is the block that halts the shipment if missing.

Finally, warnings and safety information in a language consumers understand in each country of sale. The language(s) to be used are determined by each member state, not by the seller, which is why we include all 24 official EU languages on the artwork.

Where the blocks physically go

The rule follows a hierarchy, not a choice. First, the product. If size or the nature of the product makes that impossible, then the packaging. If that is also impossible, then an accompanying document. Skipping directly to the leaflet because it is cheaper is the most common issue found in market surveillance reports.

On very small items, we produce two versions in the same order: a reduced on-product mark displaying identity and batch, and a full packaging layout with warnings and pictograms.

The five most common mistakes

Using a trade mark instead of a legal name. A logo is not a registered trade name unless it is officially registered as such.

Listing a responsible person without an address, or with an address that is a mailbox in a country where no one responds.

Machine-translated warnings, where ‘keep away from open flame’ becomes meaningless in Polish.

Text printed below the legibility threshold, at 0.8 mm, because the layout was designed before the blocks were known.

A QR code replacing printed text. Under the GPSR, a data carrier can complement the mandatory information, but never replace it.

What we deliver for this

Print-ready artwork with all blocks in place, warnings typeset in all 24 official EU languages, pictograms created as vectors, and a 1:1 proof so you can verify on paper before printing.

Each product also receives a permanent code with a public record, so when your address or warnings change, the already printed labels continue to point to the correct information.

Who qualifies as the manufacturer

The manufacturer is whoever produces the product, or has it produced and markets it under their own name or trade mark. A seller who brands goods produced by a Chinese factory is considered the manufacturer under the regulation, regardless of the internal contract terms.

This matters on the label because the block must name that company, not the factory. It also matters afterward: obligations such as technical documentation, corrective actions, and cooperation with authorities follow the name.

If a distributor modifies, re-packages, or changes the intended use of a product, the distributor becomes the manufacturer for that product. Re-labelling someone else’s goods is not a neutral act.

What an inspection actually involves

A market surveillance officer rarely begins with laboratory testing. They photograph the label, verify the blocks, request the declaration of conformity and technical file, and record how long the process takes.

A label that includes all required blocks saves time and enhances credibility. A label missing the responsible person turns a routine check into a formal file, as there is no designated contact within the Union.

Most national authorities publish their findings. A withdrawal notice with your brand’s name remains in effect long after the stock has been removed.

Online selling: timing changes, not the rules

Article 19 requires that the offer itself display the manufacturer’s details, responsible person, product identifier, and warnings before the consumer makes a purchase. The label inside the package is too late for this purpose.

This is why our artwork is designed to be photographed: one image demonstrates the blocks, and the same text is provided for marketplace fields, ensuring consistency between listing and printed label.

Where each piece goes, in order of priority

InformationOn the productOn the packagingIn a document
Manufacturer name and addressRequired firstIf the product cannot carry itLast resort only
EU responsible personRequired firstAcceptedAccepted
Type, batch or serial numberRequiredIf impossible on the productNot accepted alone
Warnings and safety informationWhere they affect useRequiredInstructions may carry the detail
Pictograms and category marksPer category rulesPer category rulesNot accepted alone

How the pieces fit

The same information, in the order an inspector or reviewer encounters it.

What goes where, in order of priority1Manufacturer name and address2EU responsible person3Type, batch or serial number4Warnings and safety information5Pictograms and category marks

Frequently used terms

Economic operator
Manufacturer, authorised representative, importer, distributor, or fulfilment service provider, as defined by the regulation.
Placing on the market
The initial act of making a product available on the Union market. It occurs once per product and triggers the obligations.
Making available
Any supply for distribution, consumption, or use in the course of a commercial activity, whether paid or free of charge.
Serious risk
A risk requiring prompt intervention, including when effects are not immediate. It activates the Safety Gate notification system.

Common questions

Does the GPSR apply to second-hand goods?

Often yes. Used, repaired, and reconditioned products placed on the EU market are covered, with limited exceptions for antiques and items clearly sold for repair purposes.

Is a website sufficient instead of a postal address?

No. The regulation requires a postal address. A URL or email address alone does not satisfy articles 9 or 16.

Can one responsible person cover multiple brands?

Yes, provided the mandate covers each brand and each product explicitly states that operator on the label.

Does a trade mark meet the name requirement?

Only if it is the registered trade name. A logo not registered as a trade name does not identify the company.

Can the importer be the responsible person?

Yes. An importer established within the Union is a valid responsible person and is the most common choice.

What if my product has no packaging?

Then the blocks must be placed directly on the product, in a reduced layout if necessary, and warnings must accompany it in the instructions.

Related guides

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