Everything You Need to Know About GPSR Marking

The GPSR has been in effect throughout the EU since December 13, 2024: Anyone selling products to private individuals must designate a responsible person in the EU and make that person’s contact information publicly visible on the product and prior to the sale.

• Authorized Representative in the EU: Every product must have a manufacturer, importer, or authorized representative based in the EU.
• Labeling: This person’s name, mailing address, and email address must appear on the product, packaging, or accompanying documentation.
• Product Identification: The type, lot, or serial number must allow for unique traceability.
• Online listings: The product page in the store or on the marketplace must include the manufacturer’s information, a product image, and warning and safety instructions.
• Language: Instructions and safety information must be provided in the language of the destination country; for Germany, this means German.
• Responsibilities in an emergency: Be able to report dangerous accidents, assess risks, and organize recalls.

What is the GPSR?

The GPSR (General Product Safety Regulation, Regulation (EU) 2023/988) is the EU’s product safety law and has been in effect in all member states since December 13, 2024.

More and more products are reaching customers through online stores, marketplaces, and direct imports from third countries. The old directive left gaps in this regard, such as when no one in the EU was liable for a product. The GPSR closes these gaps: For every product on the EU market, there must be a responsible person or company in the EU who can be contacted.

As a regulation, it is directly applicable throughout Europe.

• All products intended for end consumers that are placed on the market or made available in the EU, both online and in brick-and-mortar stores
• New, used, repaired, and refurbished merchandise, including seconds
• Online offerings aimed at end customers in the EU, including those from sellers outside the EU
• Products in B2B commerce, if they are clearly intended for consumers as well

Exceptions: These include, among other things, pharmaceuticals, food, animal feed, live plants and animals, and antiques. For products subject to specific EU regulations—such as toys or electrical appliances—the GPSR applies in addition to those regulations for aspects not covered by them. Products intended solely for export to non-EU markets are also exempt.

Who is affected by the GPSR?

The GPSR applies to anyone who imports or offers consumer products in the EU; however, the obligations depend on the role within the supply chain. Anyone who markets goods under their own name or brand is considered a manufacturer, even if they do not produce the goods themselves.

Role	Explanation	Responsibilities
Manufacturer	Anyone who develops products, has them manufactured, or distributes them under their own name or brand	Safety, technical documentation, product identification, labeling with contact information
Authorized Representative	An entity within the EU designated in writing by a manufacturer outside the EU	Maintains documentation and cooperates with authorities
Importer	Anyone who places products from third countries on the EU market for the first time	Verifies compliance and includes their own contact information on the product or packaging
Retailers	Anyone who resells products, whether online or in a brick-and-mortar store	Checks labeling and safety information; does not sell any goods that are obviously unsafe
Fulfillment Service Provider	Any entity that provides at least two of the following services for third-party goods: warehousing, packaging, addressing, and shipping (excluding postal and parcel services)	Last resort as the responsible party if no one else is based in the EU
Online marketplace	Platforms that facilitate third-party offers	Own Responsibilities: Point of Contact, Verification of Merchant Information, Reporting of Hazardous Products

The order of responsibility is as follows: manufacturers based in the EU, otherwise the importer, otherwise the authorized representative, and lastly the Fulfillment service provider.

Labeling Requirements for Products and Packaging

Every product must include four items: an identification number, the manufacturer’s contact information, the contact information of the responsible person in the EU (for non-EU manufacturers), and clear instructions, including safety precautions.

Information	Content	Placement
Product Identification	Type, batch, serial, or model number: that is, an element that allows for traceability	On the product; if the size or nature of the product does not allow this, on the packaging or in an accompanying document
Manufacturer	Name, registered trade name or trademark, mailing address, and email or website address	On the product, packaging, or accompanying documentation
Responsible Person in the EU	Name, mailing address, and email address of the importer, authorized representative, or Fulfillment service provider, if the manufacturer is not based in the EU	On the product, packaging, or accompanying document
Instructions and Safety Information	Instructions for Use and Safety Warnings, Easy to Understand	In the language of the country of sale; for Germany, German

• The mailing address is key. She must specify a location where the person can actually be reached.
• One sticker is enough. If the information is missing from the product, it may also be included on the packaging or in the accompanying documentation, in accordance with the GPSR.
• The CE marking remains separate. The GPSR does not replace product-specific markings such as the CE mark, but is in addition to them.
• Multiple destination countries mean multiple languages. Anyone who sells in Germany, Austria, and France needs safety information in German and French.

Required Information in Online Stores and on Marketplaces

According to Article 19 of the GPSR, every online offer must include four sections of information that are clearly identifiable and directly within the offer. This requirement applies to online stores, marketplaces, social commerce, and any other distance selling channel.

1. Manufacturer: Name, trade name, or brand name, as well as mailing address and email address.
2. Designated representative in the EU: Name, mailing address, and email address, if the manufacturer is not based in the EU.
3. Product Identification: A product image, as well as the type, lot, model, or serial number.
4. Warnings and Safety Instructions: All instructions that also appear on the product, in the language of the destination country.

Common problems:

• Link Instead of Specific Information: It has not been definitively clarified in law whether a “hyperlink” to the information is sufficient. If you want to be on the safe side, display the information directly on the product page.
• Marketplace Fields: Platforms have their own input fields for GPSR data. These are mandatory for merchants, as marketplaces also have their own obligations under Article 22—such as providing a central point of contact and promptly addressing security reports.
• Variant items: Each variant with its own identifier requires its own details; it is not enough to provide details only for the main item.
• Data Management: When dealing with hundreds or thousands of products, it’s worth having a centralized system for this information that automatically populates the online store, ERP, and marketplace feeds.

The person in charge in the EU: Who is it?

What matters is the first appropriate office in a fixed order, not the one that is best suited for the task. In the end, the only thing that matters to the customer is that there is an office within the EU that can be contacted and that provides information to government agencies.

If the manufacturer is based outside the EU and there is neither an importer nor an authorized representative, the role falls to the Fulfillment service provider, provided that it operates within the EU.

Here’s how to define the role in practice

• Appointment in Writing: An authorized representative is designated by the manufacturer through a written authorization and assumes the manufacturer’s obligations toward government agencies.
• Specify for each product: Who is responsible for what should be included in the product master data so that labels, the online store, and the marketplace all display the same information.
• Obtain contractual commitments: Importers and distributors should obtain written confirmation that the manufacturer will provide documentation and a point of contact.

Traceability, Accident Reporting, and Recalls

Labeling is just the tip of the iceberg: Beyond that, the GPSR requires companies to be able to act quickly in an emergency.

• Technical Documentation: Manufacturers conduct an internal risk analysis and retain documentation for ten years so that regulatory authorities can verify safety.
• Traceability: All economic operators must be able to indicate from whom they obtained a product and to whom they supplied it. Batch and serial numbers make this feasible.
• Complaint Channel: Consumers must be able to report safety issues. Manufacturers maintain a complaint registry for this purpose.
• Accident Report: If a product causes an accident resulting in serious damage, manufacturers must report it to the authorities via the European Safety Business Gateway.
• Recall: In the event of a recall, consumers must be able to be contacted directly, provided customer data is available. Purchase history and contact information from the online store thus become a safety measure. Affected customers are entitled to effective, free-of-charge remediation; they must be offered a choice of at least two out of three options: repair, replacement, or refund.

Common Mistakes and Possible Consequences

Most violations do not result from intentional actions, but rather from gaps in product data and responsibilities. Those who are aware of these gaps can close them with a manageable amount of effort.

The Five Most Common Mistakes

1. No responsible party has been designated: The manufacturer is based in Asia, and no one in the EU is responsible.
2. Information available only in the store, not on the product: Everything looks right online, but the label is missing from the package (or vice versa).
3. Incomplete master data: Manufacturer and safety fields are maintained only for bestsellers; variants are missing.
4. Safety instructions in the wrong language: English instructions are not sufficient for the German market.
5. Unclear roles with the logistics partner: No one has contractually specified who is responsible for labeling, inspecting, and taking action in the event of a recall.

Possible Consequences

Member states determine the sanctions. In practice, these may include fines, sales and distribution bans, recall orders, and the suspension of listings on marketplaces. In addition, there is the risk of warnings under competition law and, in the event of damages, increased liability, because errors in labeling and traceability make it difficult to prove that one has acted in accordance with the law.

Here’s how the IDEAL GROUP supports GPSR implementation

GPSR compliance is a collaborative effort between the brand, the retailer, and logistics—and that’s exactly where a Fulfillment partner comes in: obligations are transformed into repeatable processes. From its Heilbronn location, the IDEAL GROUP supports customers every step of the way, from master data maintenance to packages ready for shipment.

• Labeling in the warehouse: If manufacturer or importer information is missing, it can be added via labels or inserts upon receipt of goods, before a product is shipped.
• Lot and serial numbers: If you keep accurate records of goods received and shipped, you can pinpoint the affected orders in the event of a recall.
• Product Data in the Store: Using the IDEAL 360 Headless Commerce Platform, manufacturer information, safety instructions, and warnings can be maintained as separate data fields and displayed in the store and on marketplaces.
• Clear Roles: Merchant of Record models and Fulfillment agreements set out in writing who is responsible, who provides information, and who takes action in the event of an emergency.
• Packaging: With IDEAL Pack, you can design packaging and inserts that include safety information in the appropriate language.

Note: This article provides an overview and does not constitute legal advice. For definitive information regarding specific products and contracts, you should seek legal advice.