Labelling Requirements for GPSR Compliance

The General Product Safety Regulation (GPSR) applies to nearly all consumer products sold within the European Union, encompassing items such as children's products, furniture, gym equipment, textiles, and more. While many of these products are already governed by specific regulations with similar labelling requirements, the GPSR establishes overarching standards to ensure consumer safety. For reference, download our EaseCert Product Label Template.

General Labelling Requirements

Under Article 9 of the GPSR, manufacturers are obligated to provide the following information:

1. Product Identification: Each product must display a type, batch, or serial number, or another element that enables its identification. This information should be easily visible and legible to consumers. If the product's size or nature makes this impractical, the information can be provided on the packaging or in an accompanying document.
2. Manufacturer Details: Manufacturers must indicate their name, registered trade name or trademark, and both postal and electronic addresses. If a different contact point is designated, its postal or electronic address should also be provided. This information should be placed on the product; if not feasible, it can appear on the packaging or in an accompanying document.
   
   

Warnings, Instructions, and Age Suitability

Article 6 of the GPSR emphasizes the importance of clear labelling regarding:

• Age Suitability: Labels should specify the appropriate age group for the product, ensuring it aligns with safety standards.
• Warnings: Necessary warnings must be provided to inform consumers of potential risks and safe usage practices.
• Instructions for Safe Use and Disposal: Comprehensive guidelines should accompany the product to ensure its safe use and proper disposal.
  
  

Language Requirements

Per Article 22, all warning and safety information must be presented in a language easily understood by consumers in the member state where the product is marketed. This typically means providing information in the official language(s) of each country where the product is sold.

Placement of Labelling Information

The GPSR stipulates a hierarchy for the placement of labelling information:

1. On the Product: Preferably, all required information should be directly affixed to the product.
2. On the Packaging: If affixing to the product is not possible due to size or nature, the information should appear on the packaging.
3. Accompanying Document: When neither the product nor packaging can accommodate the information, it should be included in a document that accompanies the product, such as user instructions.
   
   

Responsibility for Compliance

• Manufacturers: Primarily responsible for ensuring products are correctly labelled in accordance with the GPSR. This includes companies that design products or have them manufactured under their brand by third parties.
• Importers: Required to display their name, registered trade name or trademark, and contact information on the product.

Distributors, while not specifically mentioned regarding labelling in Article 12, must ensure that products they supply comply with the GPSR's safety requirements.

Ensuring Correct Labelling

It's advisable not to rely solely on suppliers for compliance. Instead, companies should:

• Develop and provide precise label files containing all required information.
• Conduct thorough risk assessments to determine necessary warnings and instructions.
• Consult relevant product standards, which may offer specific guidance on warning texts and symbols.

Displaying EaseCert’s Contact Details

Under GPSR Article 16(3), EaseCert’s contact details must be displayed on at least one of the following:

• Product (printed label, sewn-in tag, or direct marking)
• Packaging (box, polybag, or wrapping)
• Parcel (shipping box or external packaging)
• Accompanying document (manual, compliance card, invoice, or hang tag)
• Online product listing (required by GPSR Article 19)
  
  

Choosing the Right Labelling Method

Select the most suitable method based on your business model:

• Branded apparel importer → Sewn-in labels or hang tags
• Private label clothing → Hang tags or stickers on packaging
• Online marketplace seller → Product listing + accompanying document
• Drop shipping model → Online listing + digital compliance document
  
  

Implementing Labeling at Production or Warehouse Level

A. Direct Manufacturer Labelling

• Require suppliers to print EaseCert’s details on labels, tags, or packaging.
• Include labelling requirements in supplier contracts.
• Review supplier samples to ensure compliance.
• Conduct random checks to verify correct labelling.

B. Applying Compliance Stickers at Warehouse Level

• Use pre-printed compliance stickers with EaseCert’s details.
• Train warehouse staff to apply stickers before dispatch.
• Conduct spot checks for consistency.

C. Compliance for Online Marketplaces

• Update product listings to include:
  • Manufacturer’s details
  • EaseCert’s details (if the manufacturer is outside the EU)
  • Product identifier (SKU, EAN, or model number)
  • Required safety warnings
• Provide compliance details via email or invoice upon purchase.
  
  

Recycling Symbols: What They Mean and How to Use Them

Understanding recycling symbols on packaging can be confusing, but it’s essential for proper waste management and environmental protection. Our guide explains common recycling symbols, including the On-Pack Recycling Label (OPRL), plastic resin codes, and European product markings like the CE and UKCA marks. EaseCert ensures your product labeling meets EU requirements, including safety warnings, usage instructions, and compliance markings, helping you avoid fines and support consumer clarity.

Digital Compliance Document

Providing a QR code is not sufficient to comply with the labelling obligations for GPSR products. However, a digital compliance document can be made accessible on a voluntary basis and include:

• Product Information (Name, model, SKU, batch number, images)
• Manufacturer & Importer Details (Company name and contact info)
• EaseCert’s Details (As the EU Authorised Representative)
• Declaration of Compliance (Confirming adherence to GPSR & EU regulations)
• Technical Documentation Overview (Risk assessments, safety standards, test reports)
• Safety Warnings & User Instructions (Multi-language warnings where necessary)
• Incident Reporting Process (As per GPSR Article 20)
• Digital Compliance Access (QR Code linking to compliance document)
  
  

Ongoing Compliance & Monitoring

Regular Audits:

• Review labelling and compliance documentation every six months.
• Monitor updates in EU safety regulations.

Handling Compliance Requests:

• EaseCert will provide compliance documents upon request by authorities.
• Importers must inform EaseCert of any regulatory concerns.

Incident Reporting (GPSR Article 20):

• Report safety issues to EaseCert, we will then report to the EU Safety Business Gateway.
• Online marketplaces must document and escalate consumer safety complaints.
  
  

Consequences of Non-Compliance

Failure to adhere to GPSR labelling requirements can lead to severe repercussions, including product recalls. Such actions can be costly, and there may not always be an opportunity to rectify labelling issues post-distribution.

Learn More About GPSR:

• EU Product Safety and GPSR Overview
• General Product Safety Regulation (2023) – EU Summary
• EU Safety Gate – RAPEX Alerts for Dangerous Products