Label the product with clear product traceability information that lets EU authorities and consumers identify who made the product, who is placing it on the EU market, and which Responsible Person (GPSR) is established in the EU. When the manufacturer, brand owner, and seller are different companies, you can list more than one operator, but each role must be unambiguous.
In the EU, correct EU product labeling is not just marketing. It is a compliance tool used by EU market surveillance authorities to trace products quickly, request documentation, and manage safety actions after an accident or complaint.
The questions below explain what must appear on the label, who should be named, and how to handle online sales into the EU when the manufacturer is outside the EU.
What information must appear on the product label when different companies make, own the brand, and sell it?
The label must include the product traceability information needed to identify the product and the relevant economic operators, even when manufacturing, branding, and selling are split across companies. In practice, that means a clear product identifier, the manufacturer’s name and address, and the EU-based operator details required by the General Product Safety Regulation (EU) 2023/988 (GPSR).
Because roles can overlap, the safest approach is to treat the label as a traceability map. It should allow a market surveillance authority to quickly answer three questions: What is the product, who made it, and who is the EU-based contact responsible for compliance tasks under GPSR.
- Product identification: product name, model, type, batch, serial number, or other identifier that supports traceability
- Manufacturer identification: legal name and postal address of the manufacturer
- EU contact details where required: the EU-based economic operator designated under GPSR, typically shown with name and address and a reachable contact channel
- Safety information: warnings and instructions needed for safe use in the relevant EU languages for the markets where the product is sold
Do not rely on a website only. For traceability, authorities generally expect a physical address on the product or, where permitted, on the packaging or accompanying document, depending on the product and applicable rules.
Who should be named on the label in the EU under GPSR: manufacturer, importer, brand owner, seller, or Responsible Person?
Under GPSR, the label should identify the manufacturer and the EU-based Responsible Person (GPSR) economic operator that fulfills the required EU presence role for products sold to EU consumers. The brand owner and seller can appear, but they do not replace the required operator identification. If there is an importer, importer details may also be required depending on how the product enters the EU supply chain.
To avoid confusion, match names on the label to real legal entities and real roles. A brand name alone is not the same as a legal manufacturer name. If the brand owner is not the manufacturer, do not present the brand owner as the manufacturer.
- Manufacturer: the entity that manufactures the product or has it designed or manufactured and markets it under its name or trademark
- Brand owner: may be the manufacturer, but if not, it is usually a separate economic operator that owns the trademark and controls branding
- Seller: the entity offering the product to EU consumers, often an online marketplace seller or direct-to-consumer store
- Importer: the entity established in the EU that places a product from a third country on the EU market, when an importer exists in the chain
- Responsible Person (GPSR): the EU-established economic operator shown for GPSR purposes so authorities have an EU contact point for compliance and documentation access
Also keep role boundaries straight for notifications. Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), the Responsible Person must notify risks to the manufacturer in line with Article 4, while an Authorized Representative handles notifications of serious risks to authorities when that Authorized Representative role exists. An Authorized Representative is not mandatory, but a Responsible Person is required for many non-EU sellers placing consumer products on the EU market.
How do you handle labeling when the manufacturer is outside the EU and you sell online into the EU?
When the manufacturer is outside the EU and you sell online into the EU, you must ensure the product shows the non-EU manufacturer details and also the EU-based Responsible Person (GPSR) details required for EU market access. If you ship directly to consumers with no EU importer or distributor, the Responsible Person role becomes the key EU-based operator shown for EU product labeling and traceability.
Online listings do not replace physical labeling. Marketplaces may ask for Responsible Person information in the listing workflow, but authorities still expect traceability information on the product, packaging, or accompanying documentation as applicable.
- Confirm the legal manufacturer and use the correct legal name and full postal address, not only a brand name.
- Assign the EU-based Responsible Person and prepare the exact label text for the Responsible Person name and address.
- Decide placement: on product where feasible, otherwise on packaging or an accompanying document when rules allow.
- Align the online listing with the physical label so the same operator names and addresses appear consistently.
- Keep documentation ready so it can be made available to authorities upon request, supporting product traceability and safety assessment.
If you use multiple fulfillment routes, for example direct shipping for some orders and an EU warehouse for others, review whether an importer exists in any route and whether additional operator details must be shown. Consistency across SKUs and batches matters because enforcement often starts with a single flagged listing or a single product sample.
How EARP helps with correct EU labeling when multiple companies are involved?
We help you get EU product labeling right when the manufacturer, brand owner, and seller are different companies by translating role confusion into clear, compliant label content that supports EU market surveillance expectations and product traceability information. We focus on practical, fast execution so you can keep selling while meeting GPSR requirements.
- Role mapping to confirm who is the legal manufacturer, who is the seller, and which EU economic operator will act as the Responsible Person (GPSR)
- Label content checks to ensure names, addresses, and identifiers are complete and not misleading when a brand owner differs from the manufacturer
- Documentation readiness processes to verify required product safety documents are present, stored, and available to authorities when requested
- Operational continuity as an independent EU-based compliance partner, avoiding conflicts that can arise when commercial operators try to fill compliance roles
If you want a clear labeling plan for your specific supply chain and online sales model, contact our compliance team or review our services to get started.
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