What labeling and traceability does the GPSR require on products?

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Jason van de Zande

Under the General Product Safety Regulation (EU) 2023/988 (GPSR), products sold to EU consumers must be labeled so that buyers and authorities can identify the product, contact the relevant economic operators, and understand any necessary safety warnings and instructions. The GPSR also requires clear traceability, using identifiers such as model, batch, or serial numbers. Below are the most common questions about what must appear on the product, when packaging or documents can be used, and how to set up practical traceability.

What labeling information does the GPSR require on consumer products?

The GPSR requires product identification, economic operator contact details, and any safety information needed for safe use. As a rule, information should appear on the product; if that is not possible, it should appear on the packaging; and, if necessary, in an accompanying document. For distance sales, key details must also be shown in the online offer so consumers can see them before purchase.

  • Product identifier: a type, batch, or serial number, or another element that allows the product to be identified.
  • Manufacturer details: name (or registered trade name or trademark), postal address, and an electronic address (for example, an email address or a dedicated contact page on a website that enables direct contact).
  • EU Responsible Person details (when the manufacturer is not established in the EU): name and contact details (postal and electronic address) shown on the product or, where allowed, on the packaging or in an accompanying document.
  • Importer details: where an importer is the relevant economic operator for the product, the importer’s identification and contact details must be provided under the applicable rules.
  • Warnings, instructions, and safety information: provided when needed to use the product safely, including information on safe disposal where relevant.

Language: instructions and safety information must be in a language easily understood by consumers in each Member State where the product is made available. Many businesses handle this by providing country-specific manuals or multilingual booklets and ensuring the same warnings appear consistently on the label, packaging, and online listing.

What traceability elements must be used under the GPSR (batch, serial, model)?

The GPSR expects each product to carry a traceability identifier, such as a model, batch, or serial number, so the product can be tracked and distinguished from similar items. This supports targeted corrective actions, complaint handling, and authority requests for information because you can link a specific unit or production run to its safety documentation and distribution history.

Practical approaches that usually work well:

  • Model number for product type identification across variants (useful for technical documentation organized by model).
  • Batch or lot code for production-run traceability (useful for material changes or supplier changes).
  • Serial number for higher-risk products or products with individual unit history (repairs, firmware changes, or warranty tracking).

The GPSR is a horizontal regulation, so sector-specific rules can add more specific marking requirements. For example, certain CE-marking legislation, chemicals rules, or packaging rules may require additional markings beyond the GPSR baseline. Keep identifiers consistent across the product label, packaging artwork, manuals, test reports, and online listings, because mismatches are a common reason compliance checks fail.

When can GPSR labeling be placed on packaging or documents instead of the product?

You can place required GPSR information on the packaging, or, as a last resort, in an accompanying document, when it is not possible to put it on the product due to the product’s size or nature. Even then, the information must remain easy to find, legible, and durable enough for normal handling, and it must still allow authorities and consumers to identify the product and contact the relevant economic operators.

A simple placement hierarchy to follow is:

  1. On the product itself (preferred).
  2. On the packaging.
  3. In an accompanying document (for example, an insert or manual).

For online sales, do not rely on physical packaging alone. The online offer should display the manufacturer’s identity and contact details, the EU Responsible Person’s details when required, product identification (including a picture and identifier), and applicable warnings and safety information in an easily understood language. Document your rationale when you move information off the product—for example, with photos showing limited marking space and a controlled decision record tied to the SKU or model.

How EARP helps with GPSR labeling and traceability compliance?

We help non-EU manufacturers and sellers meet GPSR labeling and traceability expectations with practical, audit-ready processes, and we can act as the EU Responsible Person where required. Our support is designed to reduce back-and-forth with marketplaces and to keep documentation and identifiers consistent across labels, listings, and technical files.

  • EU Responsible Person service aligned with GPSR and Market Surveillance Regulation (EU) 2019/1020 (MSR) role expectations
  • Label and packaging content review against GPSR identification, contact, and warning requirements
  • Traceability setup guidance for model, batch, and serial schemes that match your production reality
  • Technical documentation storage and controlled availability for authority requests
  • Liaison support with national market surveillance authorities when documentation is requested

See our services or contact us to discuss your product range and the fastest path to GPSR-compliant labeling and traceability.

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