What product identification information must appear on online listings under GPSR Article 19?

Under the General Product Safety Regulation (EU) 2023/988 (GPSR), Article 19 requires online offers to show clear product identification and key economic operator contact details before the consumer buys. In practice, your listing should enable authorities and consumers to trace the exact product, see who made it, and, where required, see the EU Responsible Person’s contact details. The questions below explain what counts as “identification,” when Responsible Person details are mandatory, and how to implement these requirements on marketplaces and D2C sites.

What does GPSR Article 19 require to be shown on an online product listing?

GPSR Article 19 requires that distance and online product offers display traceability and safety information clearly and visibly before purchase. At a minimum, the offer should identify the product, show the manufacturer’s name and contact details, and, where applicable, show the EU Responsible Person’s contact details. Any required warnings and safety information must also be shown in an easily understood language for the relevant market.

For most sellers, the practical goal is simple: a consumer and a market surveillance authority should be able to open the listing and immediately understand what the product is, who is responsible for it in the supply chain, and what safety information applies.

Product identification (enough to distinguish the exact item offered)
Manufacturer identification (name plus postal and electronic address)
Responsible Person identification (when required, with contact details)
Warnings and safety information relevant to safe use

Which product identification details count as “identifying the product” under Article 19?

“Identifying the product” means providing identifiers that allow someone to distinguish the exact product offered from similar products. In online listings, this is usually done through a combination of a product name or model and a unique code used on the product or packaging. Article 19 also expects a picture of the product as part of identification for distance offers.

Common identification elements that work well online include:

Product name and model, variant, or SKU (as presented to consumers)
Type, batch, serial number, or other unique identifier used by the manufacturer
Barcode or GTIN, where you use one in your supply chain
Clear product images that match the item actually shipped

Choose identifiers that match what is marked on the product or packaging and what you keep in your technical documentation. If you sell multiple variants, each variant should have its own identifiers and images so the online offer does not blur traceability.

When must the Responsible Person’s information appear, and what exactly should be listed?

The Responsible Person’s information must appear in the online offer when the GPSR requires a Responsible Person established in the EU for the product being made available on the EU market. The Responsible Person is an economic operator in the EU that acts as a key compliance contact point. The listing should show the Responsible Person’s name and contact details so authorities can quickly reach the correct EU-based operator.

In practice, include:

Responsible Person name (legal entity name)
Postal address in the EU
Electronic address (such as an email address or a URL-based contact route)

Do not replace manufacturer details with Responsible Person details. Article 19 expects manufacturer identification to be shown as well. Also keep role boundaries clear: under the Market Surveillance Regulation (EU) 2019/1020 (MSR), the Responsible Person must, among other tasks, inform the manufacturer when there is reason to believe a product presents a risk. However, the Responsible Person is not the role that submits serious-risk notifications to authorities; that is handled by an authorised representative when that role exists.

How can sellers implement Article 19 information on marketplaces and D2C sites without breaking platform rules?

You can meet Article 19 requirements by placing the required information in fields that are visible to shoppers and stable across edits. On marketplaces, use dedicated compliance attributes where available, and avoid hiding required details only in images or downloadable files. On D2C sites, add a structured “Product safety and compliance” section near the description, and keep it consistent across variants and languages.

Marketplaces (Amazon, eBay, Etsy): use compliance, “manufacturer,” and “responsible person” fields, then mirror key identifiers in the title or bullet points where permitted.
Variant control: ensure each child variation has the correct model, batch, or SKU mapping and the correct images.
Language: show warnings and safety information in the language(s) of the Member State(s) where you target consumers.
Evidence: keep dated screenshots or exports of listings showing Article 19 elements, in case a platform or authority asks what was displayed at the time of sale.

How [COMPANY] helps with GPSR Article 19 online listing compliance

We help you implement GPSR Article 19 listing requirements in a way that supports traceability, platform acceptance, and authority readiness, without turning your product pages into legal documents.

We act as your EU Responsible Person and provide the correct entity details to display
We review your product identification approach to ensure it matches product markings and documentation
We support documentation handling and readiness for market surveillance requests

See our services, or contact us to confirm what your listings must show for your specific products and sales channels.