GPSR · Labelling

GPSR labelling requirements: the product, the box, and the product page

Updated 24 July 20267 min readShopify and marketplace sellers shipping consumer products into the EU

GPSR splits its information rules across two places. Article 9 says what has to be physically on the product, or on the packaging if the product is too small to carry it. Article 19 says what has to appear in the online offer itself, clearly and visibly, before the customer buys. Miss the second one and a perfectly safe, properly marked product is still non-compliant, which is the version most Shopify sellers get wrong.

Organic cotton t-shirtEUR 39.00RESPONSIBLE PERSON (EU)EU Compliance Ltd, Berlin, Germanyrp@eucompliance.eu

On the product: Article 9

Manufacturers have to make the product identifiable and themselves contactable. That means:

  • A type, batch or serial number, or another identifying element, so a specific production run can be traced.
  • The manufacturer's name, registered trade name or registered trade mark, together with a postal address and an electronic address at which they can be contacted. Both, not one or the other. An email address alone does not satisfy it, and neither does a postal address alone.
  • Where the size or nature of the product makes marking impossible, the same information goes on the packaging or in a document accompanying the product. This is a fallback for small items, not a general option.

Importers add their own name, registered trade name or trade mark and postal and electronic address, and they must not do so by covering the manufacturer's markings. If you import into the EU under your own brand, you are carrying both sets of duties at once.

In the box: instructions and safety information

Products have to come with clear instructions and safety information in a language that consumers can easily understand, and the language is determined by the member state you are selling into. There is no EU-wide English default.

Germany made this explicit in 2026

The amended German Product Safety Act (ProdSG), published on 5 February 2026 and in force from 19 February 2026, spells out that instructions and safety information have to be in German. If your inserts are English-only and you ship to Germany, that is now a named national requirement, not an interpretation.

On the product page: Article 19

This is the one that catches ecommerce. Article 19 requires that any offer for distance sale shows, clearly and visibly, at least four things:

  1. (a) The name, registered trade name or registered trade mark of the manufacturer, plus the postal and electronic address at which they can be contacted.
  2. (b) Where the manufacturer is not established in the EU, the name, postal address and electronic address of the responsible person in the Union.
  3. (c) Information identifying the product, including a picture of it, its type, and any other product identifier.
  4. (d) Any warning or safety information that has to be affixed to the product, the packaging, or an accompanying document, in a language easily understood by consumers.
Organic cotton t-shirtEUR 39.00RESPONSIBLE PERSON (EU)EU Compliance Ltd, Berlin, Germanyrp@eucompliance.eu
What an Article 19 compliant product page has to show, before checkout.

Clearly and visibly means on the offer

A link in your footer, a line in your terms and conditions, or a separate compliance page does not satisfy Article 19. The information has to be part of the offer the customer sees before they decide to buy. A collapsible section on the product page is generally accepted; a different page is not.

Note what (d) means in practice for a store selling across the EU. The warnings have to be understandable in the destination country's language, so a single English block on a product page is weak for a store shipping to Germany, France, Italy and Spain. If you run Shopify Markets with translated storefronts, the safety text has to be part of what gets translated, not an afterthought bolted to the English description.

The responsible person is part of the label

GPSR does not allow a product on the EU market unless there is an economic operator established in the Union responsible for it. For a non-EU manufacturer, that is your EU Responsible Person, and their details are not just a contract in a drawer: they are a labelling item under Article 19(b). Their tasks include verifying that the technical documentation, product identification and safety information exist, keeping documentation available, and cooperating with market surveillance authorities.

If you are working out where to physically put all this on a Shopify store, we walk through it in how to add a Responsible Person to your Shopify product page.

What enforcement looks like now

GPSR itself has applied since 13 December 2024 and leaves penalties to member states, which is why the picture has only sharpened recently. Germany's amended ProdSG, in force since 19 February 2026, introduces a catalogue of 32 administrative offences covering manufacturers, importers, distributors and online marketplaces, with fines running from around €10,000 for lesser breaches to €100,000 for the most serious, such as identifying a product as dangerous and failing to take corrective action.

Enforcement powers also reach the platform layer. Authorities can order online marketplaces to remove listings for dangerous products, block access, or display warnings to consumers. For a marketplace seller, that means the practical enforcement route runs through your listings, not through a letter to your registered office.

A per-SKU checklist

  • Manufacturer name or trade mark, with both a postal and an electronic address, on the product
  • Type, batch or serial number, or another identifying element, on the product
  • Same information on the packaging or an insert where the product is too small to carry it
  • Importer details added without obscuring the manufacturer's
  • Instructions and safety information in the language of each destination country
  • Responsible Person name and full contact details shown where the manufacturer is outside the EU
  • All Article 19 items visible in the offer itself, not behind a link
  • A product image, type and identifier in the listing
  • Warnings and safety text translated in every market storefront

How Assuro helps

The hard part is not knowing the list. It is knowing which of 400 products is missing which item. Assuro connects to your Shopify store and flags, per product, what GPSR data is absent, where a Responsible Person is not on record, and which EU markets that exposes. It organizes and flags. It does not act as your Responsible Person, write your warnings, translate your safety text, or certify that a product is safe.

Frequently asked questions

Does GPSR require a specific label format or symbol?

No. GPSR prescribes the information, not a layout or a mark. There is no GPSR logo. What matters is that the required identifiers and contact details are present on the product or its packaging, and that the Article 19 items appear clearly in the online offer.

Can I put the GPSR information on a separate compliance page and link to it?

No. Article 19 requires the information to be shown clearly and visibly in the offer itself. A footer link, a terms page, or a separate compliance page does not meet it. A visible section or expandable block on the product page does.

What language do warnings have to be in?

A language easily understood by consumers, as determined by the member state. In practice that is the destination country's official language. Germany's amended Product Safety Act, in force from 19 February 2026, states explicitly that instructions and safety information must be in German.

Do I need both a postal and an email address on the product?

Yes. Article 9 requires the manufacturer's name or trade mark together with a postal address and an electronic address. One without the other is not sufficient, and the same applies to the responsible person's details in an online listing.

What are the penalties for getting labelling wrong?

GPSR leaves penalties to member states. Germany's amended ProdSG, in force since 19 February 2026, sets out 32 administrative offences with fines from roughly €10,000 to €100,000, and authorities can order marketplaces to remove listings or block access.

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