What information does GPSR Article 19 require?

GPSR Article 19: What Your Online Product Listing Must Show is clear: before a consumer buys, your distance-selling offer must visibly show the manufacturer’s identity and contact details, the EU responsible person’s details where required, product identification, and applicable safety information. The information must match the product actually offered and the market you target.

Who must comply with GPSR Article 19?

Article 19 of Regulation (EU) 2023/988, the General Product Safety Regulation (GPSR), applies to consumer products offered through distance sales. This includes an e-commerce website, marketplace, mobile app or catalogue where a consumer can order without physically inspecting the product first. The GPSR has applied since 13 December 2024; its legal text is available in Regulation (EU) 2023/988.

A distance-selling offer is the page, listing or interface through which a consumer can decide to buy. Amazon, Etsy, eBay, Shopify stores, direct-to-consumer websites and social-commerce listings may therefore be in scope when they target consumers in the European Union.

The manufacturer is the person or business that makes a product, or has it designed or made, and markets it under its own name or trade mark. The importer is the EU-established operator that places a product from a third country on the EU market. A distributor then makes the product available further down the supply chain. A fulfilment service provider may store, pack or dispatch goods, but does not automatically become the manufacturer, importer or responsible person.

Example: you ship goods from Shenzhen to an Amazon FBA warehouse in Germany. Holding stock in Germany does not remove the Article 19 information requirement from the Amazon listing. Nor does it turn Amazon or the warehouse into the responsible person for your product.

GPSR Article 19: What Your Online Product Listing Must Show

Article 19 requires the following information to be displayed clearly and visibly in the distance-selling offer. Consumers must be able to access it before they conclude the purchase, not only after ordering, inside the parcel or in a hard-to-find help section.

The manufacturer’s identity and contact details

Your listing must state the manufacturer’s name, registered trade name or registered trade mark, together with its postal address and email address. This allows consumers and authorities to identify a party responsible for the product’s manufacture.

Your shop name or seller alias will not necessarily be enough. If you sell a white-label product made by another business under your own brand, establish who legally meets the definition of manufacturer for that product. The answer depends on the facts: who designed or made it, who markets it under a name or trade mark, and whether the product has been modified.

The EU responsible person’s contact details

Where the manufacturer is not established in the EU, the offer must also show the name, postal address and email address of the EU-established responsible person, as required by Article 19. A GPSR responsible person is an EU-established economic operator with specified compliance and cooperation duties under the Regulation.

This does not mean that a software subscription automatically appoints a responsible person. An EU GPSR responsible person service becomes active only after product review, entity assignment, a signed mandate and active payment. You should also review the wider duties in our guide to the GPSR responsible person’s role and obligations.

Sufficient product identification

The listing must show an image of the product, its type and any other product identifier. Product identification must make it possible to connect the online offer to the physical item, its packaging, its warnings and the relevant compliance records.

In practice, use an accurate image and at least one usable identifier, such as:

• the model or product-range name;
• a manufacturer reference;
• a batch, serial or version number where relevant;
• an SKU or GTIN/EAN, if it genuinely identifies the variant being sold;
• colour, size, power rating or another feature that distinguishes a variant.

A photograph alone does not replace the additional identification required by Article 19. Conversely, an internal code that does not appear on the packaging or supporting records may not reliably link the listing to the actual product.

Applicable warnings and safety information

The listing must display the warnings and safety information that must accompany the product. They must be presented in a language easily understood by consumers, as determined by the Member State where the product is made available.

The content depends on the product and on any applicable sector-specific legislation. It may include an age restriction, choking-risk warning, battery precautions, installation instructions, use limits or a heat warning. Generic wording such as “use with care” does not replace product-specific safety information.

Example: a toy listing involving small parts should not rely solely on a photograph of the packaging. If a relevant warning accompanies the product, the consumer must be able to read it in the offer and in the required language for the target market.

Where should you display this information on Amazon, Shopify or a marketplace?

The GPSR says that the information must be provided “clearly and visibly” in the offer. It does not prescribe one identical page layout for every website. However, information buried in terms and conditions, a footer or a difficult-to-find PDF creates a practical risk: the consumer may not see it, and a marketplace or authority may regard it as insufficiently accessible.

On your own website, create a dedicated block such as “Manufacturer and product safety” directly on the product page. Put it before or close to the purchasing elements, rather than treating a general contact page as a substitute. A structure driven by controlled product-data fields is more reliable than text copied manually into each description.

On a marketplace, complete the regulatory, manufacturer, responsible-operator and safety fields where they are available. Then check the public page from the destination country. Information entered in the seller portal can be hidden, truncated or displayed differently depending on the marketplace.

A common mistake is to assume that data held in the seller dashboard automatically satisfies Article 19. What matters is the information actually visible in the consumer-facing offer.

How do you make product listings compliant step by step?

The safest method is to link every listing to a controlled source of product data. This reduces the risk that a change of manufacturer, variant or responsible person leaves outdated information online.

1. List the products and variants you sell in the EU. Separate references with different manufacturers, warnings or supporting documentation.
2. Identify the legal manufacturer for each reference. Collect its name, postal address and email address. Do not substitute the details of a warehouse or a simple third-party seller.
3. Determine the required EU economic operator. For a non-EU manufacturer, check whether an EU GPSR responsible person is in place and identify that person correctly. Products subject to EU harmonisation legislation may also have sector-specific requirements, including CE marking.
4. Gather product identifiers and safety information. Match each image, model, variant and warning to the item actually dispatched. Retain the source version and approved translations.
5. Adapt the information for each target country. Language and sector-specific requirements can differ. If you launch in several Member States, assess the destination markets, not only the country where stock is held.
6. Publish, then check the public display. Review the listing on desktop and mobile, including every variant. Keep a dated screenshot and schedule a review whenever the product, manufacturer or service provider changes.

To organise this review before publication, the Marketplace Product Compliance Scanner can flag traceability, safety and compliance information to check in a marketplace listing. It is a review tool: it does not certify product compliance or confirm that every obligation has been met.

EU Seller Kit — The Marketplace Product Compliance Scanner helps you identify manufacturer, responsible-person, product-identification and safety information to review in a marketplace listing before publication.

How do GPSR, CE marking and EU representation differ?

The GPSR applies generally to consumer products within its scope. Some products are also, or mainly, subject to sector-specific EU harmonisation legislation, for example electrical equipment, toys or certain personal protective equipment. The official Your Europe guidance on CE marking explains that CE marking follows specific rules for particular product categories.

A GPSR responsible person is not automatically an authorised representative under CE legislation. Equally, a CE authorised representative does not automatically fulfil the operator role required under the GPSR. The applicable role depends on the product category, the legislation concerned and the mandate actually signed.

EU Seller Kit’s CE authorised representative service, where available for the applicable legislation, operates only under a written mandate. It does not replace the manufacturer’s conformity assessment, technical documentation, required testing or EU declaration of conformity.

Imagine a US manufacturer selling a rechargeable lamp in the EU. Its online listing must meet GPSR Article 19. If the lamp is also subject to sector-specific CE requirements, the manufacturer must address those separate duties: conformity assessment, technical documentation, an EU declaration of conformity and the applicable economic-operator obligations. A single “compliance” section on the listing does not complete the wider file.

Which mistakes most often lead to a blocked listing?

Marketplaces may request further data, suspend a listing or ask for evidence when they identify missing or inconsistent information. Market-surveillance authorities can also request information from economic operators during checks under Regulation (EU) 2019/1020 on market surveillance and product compliance.

The most frequent mistakes are:

• showing only a brand name, without the manufacturer’s postal and email addresses;
• naming a responsible person that has not accepted the mandate or whose details are no longer valid;
• reusing the same warnings for products with different risks;
• missing a variant, such as a battery, size or material that changes the necessary precautions;
• publishing warnings in a language unsuitable for the destination country;
• confusing the importer, seller, logistics provider and manufacturer;
• leaving an old listing online after a change to the product, manufacturer or representative.

Inconsistent information can also make a document request harder to handle. If the reference displayed online does not match the packaging or technical file, an authority or marketplace may struggle to identify the product concerned. Maintain a stable link between the commercial reference, variant, label, images and internal records.

What should you do if you sell from outside the EU?

Start by mapping the real flow of goods: country of manufacture, storage location, destination countries, manufacturer identity and the party importing the goods. If you import products into the EU yourself, customs and VAT formalities sit alongside product obligations; they do not replace them.

An EORI number identifies economic operators for customs formalities. It is not a GPSR responsible person and does not prove that your product listing meets Article 19. EU Seller Kit offers EORI file preparation; the EORI number itself is issued by the competent customs authority, and file preparation is a one-time service unless included in a SaaS plan quota.

If you are unsure which rules apply to your product and trade flow, an EU Market Entry Compliance Assessment helps structure the points to review: customs and EORI, VAT, the GPSR responsible operator and CE legislation. It does not replace product-specific legal or technical analysis where that is needed.

Official sources

• Regulation (EU) 2023/988 — General Product Safety Regulation (GPSR)
• Regulation (EU) 2019/1020 — market surveillance and compliance of products
• Your Europe — CE marking

This content provides general information and is not legal advice.