A Product Listing Under the GPSR: the Four Blocks Without Which the Offer Is Unlawful
Most conversations about the General Product Safety Regulation start with recalls and market surveillance, which is where the drama is. For anyone running an online shop the operative provision is duller and far more immediate: a short article that says what has to appear on the offer itself. Get it wrong and the listing is non-compliant regardless of how safe the product is.
Regulation (EU) 2023/988 has applied since 13 December 2024. Article 19 is one sentence and four lettered points, and it is the part of the regulation your product template has to satisfy.
What Article 19 actually says
The wording is worth reading rather than paraphrasing, because two of the four points contain a requirement that catalogues routinely miss. Where economic operators make products available online or through other means of distance sales, the offer has to indicate clearly and visibly at least the following.
| Block | What the text requires | The part usually missing |
|---|---|---|
| Manufacturer identity | Name, registered trade name or registered trade mark, plus the postal and electronic address at which they can be contacted | The postal address. Brand plus a support email is not the same thing |
| Responsible person in the Union | Where the manufacturer is not established in the Union: the name, postal and electronic address of the responsible person | The whole block, on every listing sourced from outside the EU |
| Product identification | Information allowing identification of the product, including a picture of it, its type, and any other product identifier | Type designation and the batch or serial identifier, as distinct from your own SKU |
| Warnings and safety information | Any warning or safety information required by this regulation or applicable harmonisation legislation, in a language easily understood by consumers as determined by the member state | The language obligation, which is set by the member state where the product is made available |
Three details in that table are worth pulling out.
The address is postal and electronic, not one or the other. The regulation says “the postal and electronic address at which they can be contacted”. A brand page with a contact form does not satisfy it.
Your SKU is not a product identifier for these purposes. The point requires information allowing identification of the product, including its type and any other identifier. In practice that means the manufacturer’s type designation and, where the product carries one, the batch or serial number. An internal catalogue number identifies the listing, not the product.
The picture is mandatory. It sits inside point (c) as part of product identification, which surprises people who treat photography as a merchandising decision.
Who the responsible person is, and why the second block is the expensive one
For goods manufactured outside the Union, someone established inside it has to be nameable and contactable. The regulation points to Article 16(1) of the GPSR itself or Article 4(1) of Regulation (EU) 2019/1020 on market surveillance, which sets out the roles that can hold that function: an EU-established manufacturer, an importer, an authorised representative, or a fulfilment service provider where none of the others exists.
The commercial consequence is the part worth planning around. If you import directly, you are very likely the responsible person yourself, and your own address goes on the listing. If you buy from an EU distributor, the responsible person is somewhere upstream and you need that data as a supplied field, not as something a copywriter reconstructs. Most catalogue projects that fail on the GPSR fail here: nobody put the field in the product information model, so there is nowhere to put the answer when it arrives.
The targeting test decides whether any of this applies to you
Article 4 states that products offered online or through other means of distance sales are deemed to be made available on the market if the offer is targeted at consumers in the Union. That is the trigger, and it is not about where your company is registered.
The regulation’s recitals set out how the assessment works: a case-by-case analysis, in line with private international law, of whether the operator directs its activities to a member state. The relevant factors named are the geographical areas to which dispatch is possible, the languages available and used for the offer or for ordering, the means of payment, the use of the currency of the member state, and a domain name registered in one of the member states. Crucially, the mere fact that your interface is accessible from a member state is explicitly stated to be insufficient.
| Signal | Points away from targeting | Points toward targeting |
|---|---|---|
| Dispatch zones | No EU country selectable at checkout | Member states listed with rates |
| Language | One language, not that of any target market | A member state language version |
| Currency | Home currency only | Euro or a member state currency offered |
| Payment | Local methods only | Methods characteristic of a member state |
| Domain | Generic or home-country domain | A member state top-level domain |
No single row decides it. The assessment is cumulative, which is why a shop that added a euro price and EU shipping “just to see” has usually crossed the line without a decision ever being taken.
Where the data comes from, which is the real project
Article 19 is trivial to satisfy on one listing and hard to satisfy on forty thousand. The work is not legal drafting, it is product information management.
- Add the fields to the model, not to the description. Manufacturer name, manufacturer postal address, manufacturer email, responsible person name, responsible person postal address, responsible person email, type designation, batch or serial identifier, warnings text per language. Free-text descriptions cannot be validated, exported or audited.
- Make them required at import. A supplier feed that silently accepts blanks will produce non-compliant listings at scale, and nobody will notice until a market surveillance authority does.
- Keep the warnings per language, not per product. The language is determined by the member state where the product is made available, so a single English string does not scale across markets.
- Render them visibly. “Clearly and visibly” is not satisfied by an accordion three clicks down, and it is definitely not satisfied by a PDF datasheet.
This is a supplier data problem before it is a front-end problem, which means it lands squarely on whatever connects your catalogue to your suppliers. Our piece on connecting a website to CRM and warehouse systems covers the integration side; the reason it matters here is that the GPSR fields have to travel the same path as price and stock, and be validated with the same strictness.
Four things Article 19 does not require
The vendor commentary around the regulation has generated a set of obligations that are not in the text, and each of them costs money to implement.
- It does not require a CE mark on the listing. CE marking comes from sector-specific harmonisation legislation where it applies at all. The GPSR is the safety net for products not covered by that legislation.
- It does not require a declaration of conformity to be published. Documentation duties exist elsewhere in the regulation and are owed to authorities, not to the product page.
- It does not require a separate compliance page. The obligation attaches to the offer, which means the product page, not a policy document linked from the footer.
- It does not require you to translate the description. The language rule in point (d) covers warnings and safety information. Marketing copy is a commercial decision, and confusing the two produces translation budgets aimed at the wrong text.
Enforcement, and the Safety Gate
The regulation leaves penalties to member states. Article 44 requires them to be effective, proportionate and dissuasive, which means the number depends on where the consumer is, not where you are. That is a genuine difference from a directly applicable fine ceiling, and it makes market-by-market checking unavoidable.
Two Commission systems sit alongside the obligations. The Safety Gate is the rapid alert system for dangerous non-food products, and its public alerts database is worth searching against your own catalogue before a regulator does it for you. Providers of online marketplaces have their own registration and contact-point duties under Article 22, which are distinct from the seller duties described here and are frequently confused with them.
A short checklist
- Pick ten listings at random and score them against the four blocks. The failure rate on a catalogue that has never been checked is usually above half.
- Confirm you have a postal address for the manufacturer, not only a brand name.
- For every non-EU-manufactured item, confirm the responsible person is named and reachable.
- Confirm the type designation and batch or serial identifier are stored as fields.
- Confirm the warnings render in the language of each market you dispatch to.
- Decide deliberately whether you target EU consumers, and align dispatch, currency and language with that decision.
The same product page is now carrying several overlapping regimes at once: product safety information, accessibility duties of the kind discussed in our review of the first year of the European Accessibility Act, and national rules on pricing and language. Our walkthrough of a Bulgarian online store in 2026 shows what that stack looks like in one market. The commercial context, and what actually moves sales rather than compliance risk, is in our overview of e-commerce trends.
Practically, this is a data model change plus a template change, which is the sort of work we do when we build online stores, and the structure behind the catalogue on our Fense project is a worked example of fields carrying obligations rather than descriptions carrying them. A compliant listing is only half the journey. The step straight after it is where most of the revenue actually leaks, which we broke down in our analysis of what a checkout loses.
This article summarises the text of a published EU regulation as at August 2026. It is not legal advice, and national penalties and language requirements differ across member states.
