Can the required contact details go in the instruction manual instead of on the product?

Usually, no. Under EU product labeling requirements, the required contact details cannot be placed only in the instruction manual if the information can be put on the product or its packaging. The instruction manual is typically a fallback option, not the default, for GPSR contact details on the product.

This matters most for non-EU brands and online sellers because marketplaces and market surveillance authorities expect clear, easy-to-find manufacturer contact information EU buyers can use, plus the EU Responsible Person marking where required. If the details are buried in a manual, the product can be treated as non-compliant.

The questions below clarify what must be shown, where it can go, and how to stay compliant when label space is tight.

Can required contact details be placed only in the instruction manual?

In most cases, required contact details should not be placed only in the instruction manual. The General Product Safety Regulation (EU) 2023/988 (GPSR) expects key traceability and contact information to be provided on the product itself where possible, or otherwise on the packaging or an accompanying document. A manual alone is usually not sufficiently accessible at the point of purchase or inspection.

The practical reason is simple: authorities and consumers must be able to identify the responsible economic operator and reach them without needing to open and read a booklet. For e-commerce, the manual may not even be available before purchase, and it can be separated from the product during storage, returns, or resale.

If you are deciding between instruction manual vs product label, treat the manual as supporting material. Use it to repeat the information, add additional contact channels, and provide safety instructions, but do not rely on it as the only location unless you genuinely cannot mark the product and cannot reasonably rely on packaging.

What contact details must appear on the product, packaging, or accompanying document under the GPSR?

Under the GPSR, consumer products must include clear identification and contact details for the relevant economic operator so authorities and consumers can reach them. In practice, EU product labeling requirements typically mean showing the manufacturer name and a postal address, and where applicable the EU-based Responsible Person details, using a format that is easy to read and durable for the product type.

While exact presentation can vary by product and supply chain role, a compliant set of details commonly includes:

Manufacturer identification such as the legal name or registered trade name
Manufacturer postal address that can receive official communications
Product identification such as model, type, batch, or serial number to support traceability
EU Responsible Person marking with the Responsible Person name and EU postal address when a Responsible Person is required for the product and sales model

Many businesses also add an email address, phone number, or web contact form for customer support. That can help consumers, but it does not replace a postal address for regulatory traceability. The safest approach is to ensure the core manufacturer contact information EU authorities expect is present in a stable, verifiable form.

When is it acceptable to use packaging or an accompanying document instead of the product marking?

It is acceptable to place GPSR contact details on the packaging or in an accompanying document when marking the product itself is not possible or not reasonable due to the product’s size, nature, or surface, or when the marking would not remain legible and durable during normal use. In those cases, packaging is usually preferred over a manual.

To make this defensible in an inspection, you should be able to explain why direct marking is impractical and show that the alternative location still makes the information easy to find. Common acceptable scenarios include very small items, products with no suitable marking surface, or products where printing would wear off quickly.

Good compliance practice is to follow a hierarchy:

Product if feasible and durable
Packaging if product marking is impractical
Accompanying document if packaging is not available or not reliable for the sales model

If you sell through marketplaces, remember that packaging can be discarded in fulfillment and returns flows. That is one reason authorities often expect the most critical EU Responsible Person marking and manufacturer identification to be on the product whenever feasible.

How can you design compliant labeling when space is limited?

When space is limited, design the label so the legally essential information stays readable and permanent, and move secondary details to packaging or an accompanying document. For GPSR contact details on the product, prioritize a clear economic operator name and postal address, plus a traceability identifier, and use standardized formatting to save space without reducing clarity.

These tactics usually help while staying aligned with EU product labeling requirements:

Use a two-line structure such as name on line one and postal address on line two
Choose durable marking methods like laser etching, molded marking, or permanent printing appropriate to the material
Use accepted abbreviations carefully for street types or company legal forms, but do not abbreviate in a way that makes the address unclear
Keep one “primary” address for regulatory contact and avoid cluttering the product with multiple global addresses
Repeat details elsewhere by placing fuller contact options on packaging and in the manual, while keeping the core details on the product when feasible

If you are weighing instruction manual vs product label, a good rule is that the manual can expand, but the product or packaging should carry the minimum set that enables fast identification and contact during checks by customs, fulfillment centers, or market surveillance.

How EARP helps with GPSR contact details and product labeling compliance

To get GPSR contact details on the product and EU Responsible Person marking right the first time, we help you confirm what must appear on the product versus packaging or accompanying documents, and we align your labeling with the GPSR and the Market Surveillance Regulation (EU) 2019/1020 (MSR). We focus on clear, inspection-ready outcomes, including:

Responsible Person setup for eligible products and sales models, including the correct EU contact details to display
Label and packaging review to check placement, legibility, and durability against EU product labeling requirements
Documentation readiness checks to verify you have the required product safety documents available and complete
Practical marking guidance for small products where space is limited, including when an accompanying document is appropriate

If you want a fast, clear answer on your specific instruction manual vs product label situation, contact us via our contact page or review our services to get started.