Does GPSR require me to include a product image on my online listing?

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Jason van de Zande

The General Product Safety Regulation (EU) 2023/988 (GPSR) does not explicitly require a product image in every online listing. For distance sales, GPSR focuses on making key safety and traceability information available to consumers before purchase, such as manufacturer and EU Responsible Person details, product identification, and warnings. A product image can still be useful, and some marketplaces may require one as a platform rule.

Does GPSR require a product image on an online listing?

No. GPSR does not set a standalone rule requiring every online offer to include a product image. Instead, it requires that certain product safety and traceability information be provided to consumers when products are offered for sale at a distance, including online.

That said, “product identification” information may be presented in different ways depending on the product and the sales channel. Many online marketplaces also impose their own listing requirements, and those platform policies can be stricter than GPSR—for example, requiring a main image, specific angles, or label photos. Meeting a platform image rule is not the same as meeting GPSR, and meeting GPSR does not automatically satisfy platform rules.

What product information must be shown online under GPSR for distance sales?

For online offers targeted at EU consumers, GPSR requires that consumers be able to see key information before buying. The goal is traceability and clear safety communication, not a particular listing layout. The exact set can vary by product and by other applicable EU laws, but the core GPSR distance-sale information typically includes the items below.

  • Manufacturer identification: name (or trade name or trademark), plus a postal address and an electronic address for contact.
  • EU Responsible Person details when the manufacturer is not established in the EU: name, postal address, and electronic address.
  • Product identification: enough detail to identify the product being offered, such as type, model, and other identifiers used for traceability.
  • Warnings and safety information: any applicable warnings, instructions, and safety information that consumers need, provided in a language easily understood by consumers in the target Member State.

If your product is also covered by sector legislation (for example, CE-marking frameworks for certain product groups), additional online information obligations may apply under those rules as well.

When can a product image help meet GPSR information duties even if it is not required?

A product image is often a practical way to support compliance because it can help consumers and marketplaces verify what is being sold. Images can reinforce traceability and safety messaging, even though GPSR does not mandate an image as a formal requirement.

  • Showing label details that contain manufacturer and EU Responsible Person contact information, when that information is also provided as text in the listing.
  • Displaying warnings or key safety statements that appear on packaging or an accompanying document, especially when the product is small and labeling is placed on the packaging.
  • Confirming identifiers such as model, type, batch, or serial references, when those identifiers are visible on the product or packaging.
  • Supporting other legal markings (for products under other EU rules), such as showing CE marking where it is relevant, without treating the image as a substitute for required documentation.

Do not rely on images alone. If information must be “provided” to consumers, it should be clearly readable and accessible, and images must match the exact product and variant being offered. Also consider language needs: an image of a warning in one language does not automatically satisfy the requirement to provide safety information in the language(s) required for the Member State you target.

How does EARP help with GPSR online listing compliance?

We help non-EU manufacturers and online sellers align their listings with GPSR distance-sale information duties and the EU Responsible Person requirement, so your product information is ready when marketplaces or authorities request it.

  • We act as your EU Responsible Person and support your GPSR market access process through our services.
  • We review listing-ready traceability details, including how manufacturer and EU Responsible Person contact information is presented.
  • We help you check that warnings and safety information are present and suitable for the Member States you target.
  • We support documentation readiness and structured storage so information can be made available when requested by market surveillance authorities.

If you want help validating your EU online offer information under GPSR, contact us here: contact.

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