Can I put Responsible Person details only in the manual instead of on the packaging?
You can sometimes include the EU responsible person details in the manual, but relying on the manual alone is risky and often impractical. Under the General Product Safety Regulation (EU) 2023/988 (GPSR), the responsible person’s contact details must be shown on the product, on the packaging, or in an accompanying document. This article explains when a manual qualifies, where the details should appear, and what to do when space is limited.
Can Responsible Person details be provided only in the manual instead of on the packaging?
Yes, a manual can qualify as an accompanying document under the GPSR, but using the manual as the only place for responsible person details is usually a last-resort option. The GPSR expects the information to appear on the product where possible, then on the packaging, and only then in an accompanying document when the first two options are not feasible.
A manual works best when it is physically included with every unit and reaches the consumer at the point of sale. If your product is sold online, marketplaces may still ask for photos showing the responsible person details on the product or packaging, and a manual may not satisfy their listing checks. Customs and market surveillance authorities also typically expect the details to be immediately available without having to search through paperwork.
- Use the manual-only approach only when product and packaging marking are genuinely impractical.
- Make sure the manual is always included in the box, not provided only as a download.
- Keep the role clear: label it as “Responsible Person” to avoid confusion with the importer or manufacturer.
Where exactly must the Responsible Person name and address appear under the GPSR?
Under the GPSR, the responsible person’s name and contact details must appear on the product, on its packaging, or in an accompanying document. In practice, “contact details” typically means a postal address plus an electronic contact point, such as an email address or an online contact form, that enables direct two-way communication.
Markings should be legible, clearly linked to the product, and not obscured by stickers or over-labels. Instructions and safety information must be in a language consumers can understand in the Member State where the product is made available, and the same readability principle applies to responsible person details. If your product is also subject to sector-specific rules (for example, CE-marking legislation for certain categories), follow any stricter or more specific marking requirements those laws impose.
| Placement option | When it is typically used |
|---|---|
| On the product | Preferred when there is enough space and the marking can remain durable |
| On the packaging | Common when the product is too small or marking would affect function or safety |
| Accompanying document | Fallback when neither product nor packaging marking is feasible |
What if there is no space on the product or packaging for Responsible Person details?
If space is limited, you can still comply by using practical physical solutions that keep the responsible person details with the product. Common options include fold-out labels, peel-back labels, hang tags, small inserts, or a packaging sleeve. A QR code can help, but it should be supplementary and not the only way to access the responsible person details, since authorities and consumers must be able to see the required information without relying on digital tools.
For very small items, document why you could not mark the product or packaging and ensure the accompanying document is always present. Also avoid a common enforcement pitfall: do not mislabel the responsible person as the “importer” or “manufacturer,” and do not let marketplace listing data conflict with what is printed on the product or packaging.
- Try product marking first (even abbreviated layouts can work if legible).
- If not feasible, move to the packaging with a durable, readable print area.
- If still not feasible, use a guaranteed in-box insert or a manual page.
How does EARP help with GPSR Responsible Person labelling and documentation?
EARP helps with GPSR responsible person labelling and documentation by providing practical setup and verification to ensure your responsible person details are placed in a compliant, marketplace-ready way and your files are organized for authority requests under the Market Surveillance Regulation (EU) 2019/1020 (MSR).
- We review label and packaging artwork to confirm responsible person details are placed on the product, packaging, or a valid accompanying document.
- We help you choose space-saving formats (fold-out labels, inserts) that still meet physical information expectations.
- We maintain processes to store and make technical documentation available to authorities when requested.
- We support responses to market surveillance questions and help route risk information to the manufacturer as required under the MSR.
To discuss your product and the best compliant placement approach, use our contact page or review our services for GPSR support.
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