Labelling Requirements for GPSR Compliance

The General Product Safety Regulation (GPSR) applies to nearly all non-food consumer products placed or made available on the EU market, whether sold online or offline, and whether new, used, repaired, or reconditioned. This includes products such as toys, jewellery, textiles, furniture, electrical products, decorative items, accessories, etc. Certain product categories are excluded (e.g., food, medicinal products, and antiques).

Correct product labelling is one of the core requirements under the GPSR. Labels must provide consumers and market surveillance authorities with clear product identification, traceability information, responsible economic operator details, and relevant safety information. Depending on the product category, additional sector-specific EU requirements may also apply.

To support the practical implementation of GPSR labelling requirements, our EaseCert Product Label Template provides a practical example of how required compliance information may be structured on product labels or packaging, including product identification, manufacturer details, EU Responsible Person details, traceability elements, safety warnings, and other commonly required compliance information. The exact label content and placement requirements depend on the product type, applicable EU legislation, risk profile, intended user group, packaging format, and the countries where the product is sold.

Core GPSR Labelling Requirements

Under the GPSR, product labelling must allow consumers, market surveillance authorities, distributors, importers, and online marketplaces to identify the product, the responsible business, and the relevant safety information. The exact label content depends on the product type, intended user, foreseeable risks, sales channels, and the countries where the product is made available.

As a general rule, GPSR labelling should cover the following elements:

1. Product identification: Each product must display a type, batch, serial number, model number, SKU, lot code, or another element that allows the product to be identified and traced. This information must be visible and legible. If the product size or nature makes direct marking impractical, the information may be provided on the packaging or in an accompanying document.
2. Manufacturer details: The manufacturer must provide its name, registered trade name or trademark, postal address, and electronic address. If a separate contact point is used, the relevant postal or electronic address should also be provided.
3. Importer details, where applicable: If the product is imported into the EU by an importer, the importer must also indicate its name, registered trade name or trademark, postal address, and electronic address.
4. EU Responsible Person details, where applicable: If the manufacturer is not established in the EU and the product requires an EU-based responsible economic operator under the GPSR framework, the EU Responsible Person details must also be available in line with the applicable placement rules.
5. Warnings and safety information: Products must include the warnings, age grading, instructions, limitations of use, or disposal information needed for safe consumer use.

Product Identification and Traceability

Product identification is one of the most important GPSR requirements. A compliant label should allow the product to be traced back to the relevant product group, production batch, supplier, material specification, technical file, and Declaration of Conformity or compliance statement.

Suitable identifiers may include:

• Batch number or lot number
• Serial number
• Model number
• SKU or article number
• EAN, GTIN, or barcode
• Production date or production run code, where appropriate

The identifier should match the supporting technical documentation. A label that contains a batch number is only useful if the business can connect that batch number to the relevant product documentation, supplier records, test reports, and risk assessment.

Manufacturer and Importer Information

The manufacturer is primarily responsible for placing a safe product on the EU market and for ensuring that the required product information is available. This includes companies that manufacture products themselves, as well as companies that have products designed or manufactured under their own name, brand, or trademark.

The manufacturer details should normally include:

• Legal company name
• Registered trade name or trademark, where applicable
• Full postal address
• Electronic address, such as an email address or website contact address

If an importer places a product from a non-EU manufacturer on the EU market, the importer details must also be included. The importer role is separate from the EU Responsible Person role. In many supply chains, the importer is the EU business placing the goods on the market, while the EU Responsible Person supports the GPSR obligations for products from non-EU manufacturers.

Warnings, Instructions, and Age Suitability

GPSR labelling must reflect the actual risk profile of the product. Warnings should not be added randomly or copied from unrelated products. They should be based on the product design, intended users, foreseeable misuse, materials, packaging, applicable standards, and risk assessment.

• Age suitability: Labels should specify the appropriate age group where age grading is relevant to product safety. This is especially important for children’s products, toys, craft items, accessories, and products that may present choking, strangulation, sharp edge, small part, or misuse risks.
• Warnings: Necessary warnings must inform consumers of relevant risks and safe usage practices. The wording should be clear, specific, and proportionate.
• Instructions for safe use and disposal: Products should be accompanied by clear instructions where needed for safe assembly, use, maintenance, storage, cleaning, or disposal. Packaging compliance obligations may also apply separately under Extended Producer Responsibility (EPR).

Language Requirements

Warning and safety information must be provided in a language easily understood by consumers in the EU Member State where the product is made available. In practice, this usually means the official language or languages of each country where the product is sold.

For online sales across several EU countries, language coverage should be planned before the product is listed. A product sold in Germany, France, Italy, Spain, and the Netherlands may need different language coverage than a product sold only in Ireland or Malta. Businesses should avoid using one English-only label for all EU countries unless this is clearly appropriate for the specific sales market and product type.

The EU’s Safety Gate 2025 report shows strong product-safety enforcement across Europe. Our post about Europe’s Most Active Product-Safety Authorities in 2025 explains which national authorities filed the most alerts, how this affects GPSR labelling and documentation, and how businesses can apply a practical and proportionate language strategy.

Placement of Labelling Information

The GPSR follows a practical placement hierarchy. Required information should be placed where consumers and authorities can access it easily. The preferred placement is on the product itself, but this is not always possible because of product size, material, shape, surface, hygiene requirements, aesthetics, or technical limitations.

1. On the product: Required information should be placed directly on the product where this is technically possible and appropriate. Examples include printed labels, sewn-in labels, engraved markings, direct printing, adhesive labels, or durable tags.
2. On the packaging: If direct product marking is not possible or not practical, the information should appear on the packaging, such as a box, carton, sleeve, pouch, polybag, wrap, insert card, or retail label.
3. In an accompanying document: If neither the product nor the packaging can accommodate all required information, the information may be included in an accompanying document, such as a manual, safety leaflet, compliance card, hang tag, or instruction sheet.

This hierarchy applies to general product labelling information. It should not be confused with the separate requirement to provide EU Responsible Person details where applicable. In practice, both sets of information should be coordinated so the final label is clear, complete, and not overloaded.

EU Responsible Person Details and EaseCert Contact Information

For products where EaseCert is appointed as the EU Responsible Person, the label or accompanying compliance information should clearly identify EaseCert as the EU-based responsible economic operator. If EaseCert’s name and address appear on packaging or documentation, the underlying technical documentation, risk assessment, Declaration of Conformity or compliance statement, label content, and traceability records must also be aligned. Displaying the EU Responsible Person details is not only a formatting step. It creates a compliance link between the product, the appointed responsible person, and the supporting technical file.

Implementing Labelling at Production, Warehouse, and Marketplace Level

GPSR labelling should be built into the normal product handling process. The most reliable approach is to decide where the required information will appear before production, packaging, warehousing, or marketplace listing begins. This helps avoid relabelling work, customs delays, listing removals, and inconsistent product information across sales channels.

Direct Manufacturer Labelling

Where possible, the manufacturer or supplier should apply the required GPSR information during production or packaging. This is usually the cleanest option because the label becomes part of the standard product presentation.

• Require suppliers to print the required manufacturer, importer, EU Responsible Person, product identification, and safety information on the product label, packaging, tag, insert, or manual.
• Include the agreed labelling requirements in supplier instructions, purchase orders, product specifications, or supplier contracts.
• Review pre-production samples, packaging proofs, and label artwork before mass production.
• Check that the printed product identifier matches the technical documentation, risk assessment, and batch records.
• Conduct random checks after production to confirm that the approved label version is being used consistently.

Applying Compliance Stickers at Warehouse Level

If manufacturer-level labelling is not possible, a warehouse-level sticker process may be used. This can be practical for products already manufactured, products imported in plain packaging, or products where final market language coverage depends on the destination country.

• Use pre-printed compliance stickers with the required product identification, manufacturer details, importer details, EU Responsible Person details, and safety information.
• Train warehouse staff to apply stickers before dispatch to EU customers or before products are sent to fulfilment centres.
• Make sure stickers are legible, durable, securely attached, and placed where consumers can reasonably find them.
• Keep records of the sticker version used for each product group, batch, or SKU.
• Conduct spot checks to confirm that labels are applied consistently and that no outdated label versions remain in use.

Compliance for Online Marketplaces and Distance Sales

For online sales, GPSR compliance does not stop at the physical label. Product listings must also display the required information clearly and visibly before the consumer completes the purchase. This is especially important for Amazon, Etsy, Shopify, eBay, TikTok Shop, and other online sales channels.

Online product listings should include, where applicable:

• Manufacturer’s name, postal address, and electronic address
• Importer’s name, postal address, and electronic address, where applicable
• EU Responsible Person details, where the manufacturer is outside the EU and an EU-based responsible economic operator is required
• Product identifier, such as SKU, EAN, GTIN, model number, batch code, or article number
• Product images that match the actual item sold
• Required safety warnings, age grading, and user instructions
• Relevant language versions for the countries where the product is sold

Providing compliance information only by email or invoice after purchase is not enough for online sales where Article 19 information must be visible before purchase. However, invoices, manuals, inserts, and digital compliance pages can support the overall compliance file when used together with proper product labelling and marketplace listing information.

Understanding EU GPSR Label Symbols for Consumer Products

Our label symbols guide explains common label symbols used for EU consumer products, including CE marking, WEEE, EU Responsible Person information, batch codes, recycling symbols, and other product or packaging markings. It also covers resin identification codes for packaging, language requirements, and practical steps to reduce customs, marketplace, and market surveillance issues.

Symbols should only be used where they are legally required, technically correct, and supported by the underlying compliance documentation. For example, CE marking must not be used for products that are not covered by CE-marking legislation. Recycling symbols and environmental markings should also be reviewed separately from product safety warnings because they usually relate to packaging, waste sorting, or EPR obligations rather than product safety.

Recycling Symbols, Packaging Marks, and Environmental Labelling

Packaging markings can be confused with product safety markings, but they serve a different purpose. Product safety labelling helps consumers use the product safely. Packaging and recycling symbols help consumers sort packaging correctly and support national waste management and EPR systems.

Understanding recycling symbols on packaging can be difficult, but they are important for compliance, consumer clarity, waste sorting, and environmental obligations. Our guide explains common recycling symbols, including plastic resin codes, the Green Dot, and country-specific systems such as France’s Triman label.

In France, packaging subject to Extended Producer Responsibility (EPR) must display the Triman logo together with Info-Tri sorting instructions. Learn more about Triman & Info-Tri labelling requirements and how to stay compliant. It is important to distinguish environmental labelling from product safety marking. The CE mark relates to product safety legislation, while packaging EPR relates to environmental financing, registration, reporting, and waste management obligations.

EaseCert supports companies with environmental packaging compliance and broader EU regulatory alignment, including guidance on the EU Packaging and Packaging Waste Regulation (PPWR). If you place packaged goods on the French market, you must register under the national packaging EPR scheme before selling. EaseCert can assist through our France EPR Packaging Compliance Service, including registration, reporting, and labelling alignment.

For Germany, companies must register in the LUCID packaging register before placing packaging on the market. See our LUCID registration guide or use our LUCID Registration Service for practical support. Proper packaging labelling and EPR setup help reduce the risk of fines, marketplace suspensions, blocked listings, and non-compliant packaging claims.

GPSR and Other Product-Specific EU Regulations

Many products are also subject to additional sector-specific EU legislation with separate labelling, testing, documentation, chemical, or conformity requirements. For example, textile products sold in the EU must comply with Regulation (EU) No 1007/2011, which requires the use of approved fibre names and specific language rules for textile labelling. Textile products therefore need to comply with both the GPSR and the EU Textile Regulation at the same time. The GPSR does not replace product-specific legislation. Instead, it applies alongside it and adds broader obligations related to product safety, risk assessment, traceability, responsible economic operators, safety warnings, consumer information, and corrective actions.

Digital Compliance Documents and QR Codes

Article 19 of the GPSR requires economic operators selling products online or through distance sales to clearly and visibly display specific information before purchase. This includes manufacturer details, responsible person details where applicable, product identification, and warning or safety information.

A QR code can support compliance, but it cannot replace mandatory physical label information where the GPSR requires that information to appear on the product, packaging, parcel, or accompanying document. A digital compliance document should therefore be treated as an additional compliance tool, not as a substitute for required labelling.

A voluntary digital compliance document may include:

• Product information, including product name, model, SKU, batch number, images, and product category
• Manufacturer and importer details, including legal company name, postal address, and electronic contact details
• EaseCert details, where EaseCert acts as the EU Responsible Person or EU Authorised Representative for the relevant product
• Declaration of Compliance or Declaration of Conformity reference, where applicable
• Technical documentation overview, including risk assessment, applicable standards, test reports, and supplier declarations
• Safety warnings and user instructions, including multilingual versions where required
• Incident reporting process under GPSR Article 20
• QR code or web link providing digital access to supporting compliance information

Ongoing Compliance and Monitoring

GPSR labelling is not a one-time artwork exercise. Labels, warnings, instructions, and online listings must remain aligned with the actual product, supplier, materials, production site, packaging, sales countries, and technical documentation. If any of these elements change, the label and risk assessment may need to be reviewed.

Regular Label and Documentation Reviews

• Review labelling and compliance documentation regularly, especially when suppliers, materials, designs, claims, packaging, or sales markets change.
• Check that online listings match the physical product label and the technical file.
• Monitor updates in EU product safety, packaging, textile, chemical, and sector-specific rules.
• Keep old and new label versions under version control so the business can show which label applied to which product batch.

Handling Authority and Marketplace Compliance Requests

• Compliance documents should be available when requested by EU market surveillance authorities, customs, online marketplaces, fulfilment partners, or distributors.
• Importers, manufacturers, and distributors should inform EaseCert promptly of regulatory concerns, product complaints, authority requests, marketplace notices, or safety issues.
• Supporting documents should be kept in a structured technical file, including risk assessment, product description, label artwork, warnings, instructions, test reports, supplier declarations, and traceability records.

Incident Reporting under GPSR Article 20

• Safety issues, serious product incidents, or evidence of unsafe products should be escalated immediately for review.
• Where reporting is required, EaseCert can support the communication process with the relevant EU Safety Business Gateway procedures for products covered under its service scope.
• Online marketplaces must document and escalate consumer safety complaints and should ensure that product listings, warnings, and traceability records remain available.

Consequences of Non-Compliance

Failure to meet GPSR labelling requirements can lead to serious consequences, including product recalls, customs delays, marketplace listing removals, distributor refusals, authority investigations, consumer complaints, and reputational damage. Relabelling after distribution is often difficult, expensive, and sometimes not accepted as a full corrective action if the product has already reached consumers.

Correct labelling should therefore be handled before products are placed on the EU market. A defensible GPSR label should match the risk assessment, technical file, product identifiers, language requirements, online listing, and responsible economic operator details.

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