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, stubborn part is about what must be printed on the thing itself.

Example of the label this guide describes
Fac-simile of the file we deliver. Specimen data, invented 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 a document accompanying it. 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 has to narrow the goods down to a production run.

Article 16 adds the economic operator established in the Union — the responsible person — with their own name and postal address. For goods coming from outside the EU this is the block that stops the shipment when it is missing.

Finally, warnings and safety information in a language consumers understand in each country of sale. Which language counts is decided by each member state, not by the seller, which is why we put all 24 on the artwork.

Where the blocks physically go

The rule is a hierarchy, not a choice. First the product. If size or the nature of the product makes that impossible, the packaging. If that is impossible too, an accompanying document. Skipping straight to the leaflet because it is cheaper is the most common finding in a market surveillance report.

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

The five mistakes we see most

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

A responsible person named without an address, or with an address that is a mailbox in a country where nobody answers.

Warnings translated by machine, where 'keep away from open flame' becomes something that means nothing in Polish.

Text under the legible threshold, printed 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, never replace it.

What we deliver for this

Print-ready artwork with every block in place, the warnings typeset in all 24 official EU languages, pictograms drawn as vectors, and a 1:1 proof so you can check it on paper before the print run.

Each product also gets a permanent code with a public record, so when your address or a warning changes, the labels already printed keep pointing at the right information.

Who counts as the manufacturer

The manufacturer is whoever makes the product, or has it made and markets it under their own name or trade mark. A seller who puts their brand on goods produced by a Chinese factory is the manufacturer in the eyes of the regulation, whatever the contract says internally.

That matters on the label, because the block has to name that company, not the factory. It also matters afterwards: the obligations that follow the name — technical documentation, corrective action, cooperation with authorities — follow it too.

Where a distributor modifies a product, repackages it or changes its intended use, the distributor becomes the manufacturer for that product. Relabelling somebody else's goods is not a neutral act.

What an inspection actually looks like

A market surveillance officer rarely starts with a laboratory. They photograph the label, check the blocks, ask for the declaration of conformity and the technical file, and write down how long the answer took.

A label that carries every block buys time and credibility. A label missing the responsible person turns a routine check into a file, because the officer now has nobody established in the Union to write to.

Most national authorities publish their findings. A withdrawal notice with your brand on it outlives the stock it concerned.

Online selling changes the timing, not the rules

Article 19 requires the offer itself to show the manufacturer's details, the responsible person, a product identifier and any warnings, before the consumer buys. The label in the box is too late for that purpose.

This is why our artwork is designed to be photographed: one image proves the blocks, and the same text is supplied for the marketplace fields, so the listing and the print agree.

What goes where, 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 a reviewer meets it.

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

Words that keep coming up

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

Questions people ask

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 to be repaired.

Is a website enough instead of a postal address?

No. The regulation asks for a postal address. A URL or an email address alone does not satisfy article 9 or article 16.

Can one responsible person cover several brands?

Yes, if the mandate is in place for each of them and each product names that operator on the label.

Does a trade mark satisfy the name requirement?

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

Can the importer be the responsible person?

Yes. An importer established in the Union is one of the operators that can take the role, and is the most common choice.

What if my product has no packaging?

Then the blocks go on the product, in a reduced layout if necessary, and the warnings travel with it in the instructions.

Related guides

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