Labeling Requirements for GPSR Compliance
If you are a manufacturer based outside the EU and selling consumer goods in the 27 countries of the European Union, Norway, Iceland and Liechtenstein, clear and compliant product labeling is a legal requirement and one of the first things market authorities check.
ANSWERED ON THIS PAGE
- What the GPSR expects on labels
- Where to identify and list manufacturer and Authorized Representative (AR) details on the label?
- Can I use digital labeling or a QR Code instead?
- How these rules apply to e-commerce, 3PL, and Amazon sellers?
As an EU-based Authorized Representative, EARP helps non-EU manufacturers meet these labeling requirements and serves as their legal point of contact under the General Product Safety Regulation (EU) 2023/988 GPSR and Market Surveillance Regulation (MSR) (EU) 2019/1020.
What the GPSR expects on labels
Mandatory identity & traceability
Product Identification: As required by Article 9(5) of the GPSR, products must be labeled with details that allow for their identification, such as a product type, model, batch, or serial number. This ensures traceability for market surveillance authorities. This information must be easily visible and legible to consumers.
Manufacturer Identification: Under Article 9(6), the manufacturer must indicate their name, postal address, and an “electronic address” a contact point enabling direct communication (e.g. monitored email or contact form). A static web address or phone number alone does not meet this requirement.
EU Importer Identification: If an EU-based importer is involved in the supply chain, their details must also appear on the label in accordance with Article 11(3). That information shall be placed on the product or, where that is not possible, on its packaging or in a document accompanying the product
Responsible Person Identification: Where an Authorized Representative or other economic operator has been formally designated as the Responsible Person (Article 16), their full legal name and both postal and electronic address must also be included on the product label (Article 16(3)). This allows authorities and consumers to quickly reach a responsible party in the EU.
If EARP is appointed as your Authorized Representative and also assumes the role of Responsible Person, in addition to listing our postal address, it will also include an “electronic address”, i.e. a link to our online report form as required by the GPSR and where consumers can report safety issues associated with your products
Safety info, warnings & age suitability
To ensure safe use, Article 6 of the GPSR requires clear labeling on age suitability, safety warnings, and where applicable user instructions. This includes:
- Clear instructions for safe assembly, use, or disposal
- Specific safety warnings (e.g. “Keep away from fire”)
- Markings for age restrictions (e.g. “Not suitable for children under 3 years”)
These details must be easy to understand and written in the language(s), as determined by the Member State where the product is sold (GPSR Article 9(7)). Information provided with the product needs to be easily understood by consumers, It is thereby required that all information is presented in a way that is visible, legible, and durable.
Language
The GPSR does not mandate a single language across all Member States. However, Article 9(7) requires that labeling information, including safety warnings and instructions are provided in a language “easily understood by consumers.” Your risk assessment should determine if any information such as the user instructions should as a minimum be translated into the official language(s) of the Member State where the product is made available and/or put into service.
Warnings and cautions should always be translated in the language(s) of the country where the product is made available and/or put into service. You will need to check what the legal language requirements are for labeling and documentation that accompanies the product in each EU member state and Norway, Iceland and Liechtenstein.
Where should this information appear?
The labeling should follow the priority placement sequence set out in the regulation:
- On the product itself
- If not possible, on the packaging
- If that is also not feasible, in the accompanying documentation such as the instructions for use
If the space on the product is limited due to size, it is acceptable to move this information to the packaging labeling or accompanying documents, but the rationale must be justifiable (e.g., physical size, not aesthetics).
The same rules apply whether your product is sold in retail stores or via online marketplaces like Amazon, and through retail stores, or via fulfillment service providers.
Can I use digital labeling or a QR Code instead?
No. The European Commission has confirmed that a digital label such as a QR code cannot replace physical labeling. Article 21 confirms that digital labeling is allowed only as a supplement, not as a substitute. Physical labels remain mandatory under all circumstances, including for products sold exclusively online. This ensures that consumers and authorities can access critical safety and contact information regardless of how the product is distributed.
What if I use a fulfillment center or 3PL?
Using a fulfillment service provider (FSP) does not remove your labeling obligations. As the manufacturer, you remain legally responsible for ensuring all required labeling is applied before products are shipped out of the door. If there is no importer or distributor who assumes the role of Responsible Person, then a formal appointment of an Authorized Representative, such as EARP, is required under Article 16(1). FSPs can take on the role of the RP under the GPSR, but only if they take on the necessary compliance duties in a written mandate with you.
How EARP Supports
As your appointed Authorized Representative and Responsible Person, EARP ensures that your labeling fulfills the traceability and contact point requirements set out in Articles 9,10 and 16 of the GPSR. our services include
- Clarification on when and where EARP must appear on your label
- Guidance on labeling layout and placement
- A compliance checklist to review before printing of labeling
- Review of draft product and packaging labeling
We help ensure that your product meets labeling standards across all EU sales channels. More information about EARP’s Representation services.
GPSR Labeling FAQs
Only if it is technically impossible to include the information on the product and/or its packaging (Article 9(6)).
Yes. The manufacturer’s contact information is always required (Article 9(6)), and the Responsible Person’s details must be included if they have been appointed under Article 16(3). These are distinct roles and must not be combined unless one entity performs both which is only possible if the manufacturer has a legal entity in the EU.
The role of Responsible Person can be handled by an EU based importer or distributor. However if they refuse to take on the role of the RP, you must select an Authorized Representative who will act as the RP. If there is no importer or distributor(s) in your supply chain and sell direct to the end user (e.g. online sales or via Amazon or Ebay, then you will also be required to appoint an AR specifically to act as the Responsible Person.
Non-compliant labeling can lead to customs detentions, removal from sales platforms, safety alerts under Safety Gate, or market withdrawal. It may also expose the manufacturer to penalties and fines under Article 44.
The manufacturer is always responsible for ensuring labeling compliance, including ensuring that all required details are accurate and properly placed (Article 9(6)). However, the Responsible Person must verify this compliance under Article 16(2)(a).
