What Product Information Must an EU Online Listing Show Under the GPSR?

What is GPSR Article 19?

The GPSR has applied since 13 December 2024. It is an EU Regulation and is directly applicable in Member States. Article 19 addresses information in distance-sales offers. It applies where economic operators make products available on the market online or through other means of distance sale.

Article 4 says a product offered for sale online or by another means of distance sale is deemed made available on the EU market when the offer is targeted at consumers in the EU. An online interface being technically accessible from the EU is not enough by itself. Targeting may be shown by factors such as the geographic areas to which dispatch is possible, the languages offered for ordering and payment, or use of a domain associated with a Member State.

Article 19 is short but operationally important. The consumer must be able to see the required information in the offer before purchase. It is not enough that the information will arrive on the physical pack.

Which online offers are affected?

The GPSR is the horizontal EU product-safety framework for consumer products. It applies to products placed or made available on the market, whether new, used, repaired or reconditioned, insofar as there are no specific provisions of EU law with the same safety objective governing the products concerned.

For products subject to EU harmonisation legislation, the GPSR applies to aspects, risks or categories of risk not covered by that legislation. Article 19 itself expressly recognises that applicable EU harmonisation legislation may require warnings or safety information. A seller therefore needs a scope decision, not the assumption that one generic checklist governs every product.

Some product categories are outside the GPSR's scope, and product-specific law may add, modify or displace parts of the horizontal regime. Before activating listing fields, identify:

• the product and intended or reasonably foreseeable consumer use;
• whether the distance-sale offer targets EU consumers;
• the EU product-safety legislation that applies;
• the manufacturer and, where needed, EU responsible person; and
• the warnings or safety information required for that product and destination market.

This page translates Article 19. It is not a complete GPSR or sector-compliance assessment.

Information the offer must show

The phrase “clearly and visibly” is a publication requirement, not merely a storage requirement. The Article 19 information needs to be presented in or through the offer so the consumer can find and understand it before ordering.

The Commission's 2025 business guidelines reproduce the Article 19 fields and explain that electronic addresses should enable direct and effective communication. They also warn that information shown only within an image may be inaccessible to people using text-to-audio tools. A robust implementation therefore uses readable, structured text for legal actor details and warnings, while also supplying the required product picture. Accessibility is an implementation quality and guidance point; Article 19 itself states the clear-and-visible outcome.

1. Manufacturer

The offer must indicate:

• the manufacturer's name, registered trade name or registered trade mark;
• the manufacturer's postal address; and
• the manufacturer's electronic address.

Use the legal manufacturer record. A consumer-facing brand is not a substitute unless it is the relevant registered trade name or trade mark of the manufacturer and the rest of the manufacturer information is accurate.

The Commission guidance explains that an electronic address can be an email address or a dedicated section of a website through which the public can communicate directly and effectively with the manufacturer. A bare homepage that provides no direct route for communication is not enough. The electronic address is not the same thing as the postal address and both are required.

Where several premises or websites exist, publish the address selected for the legal obligation and keep the source and approval behind it. Avoid allowing a retailer to infer an address from an invoice or marketing footer.

2. EU responsible person where the manufacturer is outside the EU

If the manufacturer is not established in the EU, Article 19 requires the offer to indicate the name and postal and electronic address of the responsible person established in the EU.

This is additional to the manufacturer information, not a replacement for it. The listing should make the roles distinguishable.

Under Article 16 GPSR and Article 4 of Regulation (EU) 2019/1020, the responsible economic operator can be, depending on the supply chain:

Do not use “brand”, “seller”, “distributor”, “warehouse” or “marketplace” as though those words automatically identify the responsible person. Do not state that every non-EU manufacturer must appoint an authorised representative: an importer or, in the prescribed circumstances, another listed actor may fulfil the role.

An importer does not appear as a separate Article 19 field merely because it is an importer. Its details appear under Article 19(b) when it is the applicable responsible person. Other legislation may create additional requirements.

3. Product identification

Article 19 requires information allowing the product to be identified, including:

• a picture of the product;
• the type of product; and
• any other product identifier.

“Including” matters. Treat the picture, type and other identifier as elements of the identification set, not as alternatives from which to choose one. The offer should identify the exact product or variant that the consumer will receive and connect it to the manufacturer, responsible-person and warning records.

The GPSR does not say that the Article 19 identifier must be a GTIN, SKU, model number, serial number, batch number, Digital Product Passport unique product identifier or QR code. One or more of those may be useful or required elsewhere. For Article 19, the test is whether the information allows the offered product to be identified, alongside the picture and type.

A retailer's internal SKU can help route data without necessarily being the identifier that best connects the consumer offer to the physical product and compliance record. Conversely, a GTIN does not by itself solve variant imagery, warnings or actor identity. Maintain explicit mappings rather than collapsing every identifier into one field.

4. Warnings and safety information

The offer must show any warning or safety information that must be affixed to the product, packaging or an accompanying document under the GPSR or applicable EU harmonisation legislation.

This is not a command to put every instruction, manual or internal risk-control record onto every listing. The relevant content is the warning and safety information that the applicable law requires for that product. Article 9 GPSR itself says clear instructions and safety information are not necessary where the product can be used safely and as intended without them. Sector-specific legislation may require particular warnings even where the horizontal GPSR does not.

The Article 19 warning and safety information must be in a language consumers can easily understand, as determined by the Member State in which the product is made available. Language therefore belongs to the destination-market activation rule. Do not attach the same language to every EU channel by default.

The physical label or leaflet is not a substitute for online visibility. A consumer shopping remotely cannot inspect the packaging before purchase. Publish the applicable content clearly in the offer, and do not hide critical warnings solely in a low-resolution picture or an inaccessible download.

What Article 19 does not require on the listing

Article 19 says “at least”, so other EU or national product law can add information. But the following are not standalone Article 19 listing fields merely because the GPSR regulates or a business may need them:

This boundary prevents two errors: overloading product pages with every compliance artefact, and omitting the four Article 19 groups because information exists somewhere in a back-office file.

GPSR and other sector legislation

The GPSR does not erase product-specific safety law. Its general rules apply where specific EU safety provisions with the same objective do not cover the aspect or risk concerned. Electrical equipment, toys, cosmetics and other regulated categories can carry additional marking, warning, instruction or online-information rules. Some categories are excluded from the GPSR altogether.

Build the listing requirement from a legal applicability matrix:

1. identify the product category and destination market;
2. identify the GPSR provisions that apply;
3. identify applicable EU harmonisation and sector legislation;
4. identify mandatory warning and language rules; and
5. activate the combined, non-duplicative set for the channel.

Do not label sector-law data as “required by GPSR Article 19”. Record the source and legal basis so the requirement can be maintained when legislation changes.

Marketplace, merchant and platform distinctions

Article 19 is framed around economic operators making products available online or through distance sales. The information has to appear in the offer.

Article 22(9) creates a related duty for providers of online marketplaces: they must design their interfaces so traders can provide the Article 19 information and so it is displayed or otherwise easily accessible to consumers on the listing. That interface duty does not convert the marketplace into the manufacturer or relieve the relevant trader and economic operators of their product obligations.

Marketplace fields often use platform-specific names, validation rules and character limits. A platform may also impose policy fields beyond the legal minimum. Preserve the distinction between:

• the legal fact, such as the manufacturer's electronic address;
• the legal source, such as Article 19(a);
• the channel field used to publish it; and
• the platform rule that may impose an additional gate.

A rejected listing is not proof that a new legal obligation exists. It may reflect missing Article 19 data, a sector rule, a marketplace policy or a data-mapping error.

A practical ecommerce data model

The legal obligation describes information and an outcome. The following implementation model adds governance fields so the correct information reaches every offer. Governance fields marked “operational” are not themselves words required by Article 19.

Model actors separately from postal and electronic addresses. One manufacturer can cover many products, but its address can change. The relationship needs effective dates and approval. Model warnings as reusable, versioned content with product and market scope rather than a single uncontrolled text box.

How to manage the information across channels

The same governed facts may need to reach a brand website, retailer, online marketplace, distributor, ecommerce feed and mobile storefront. Manual re-entry creates differences in legal names, stale addresses, missing translations and warnings attached to the wrong variant.

A disciplined activation process looks like this:

1. Decide scope. Record the product, destination market and legislation that makes each field applicable.
2. Resolve the actors. Verify the legal manufacturer and, where the manufacturer is outside the EU, the correct responsible person and the products covered.
3. Identify the product. Connect the picture, type and chosen identifier to the physical product and each sellable variant.
4. Approve safety content. Obtain the applicable warnings and safety information from the authorised compliance source, with destination languages.
5. Map channels. Connect governed facts to each platform's fields without changing their meaning.
6. Validate the offer. Check clear and visible presentation on the live page, including mobile and assistive access, not only feed acceptance.
7. Monitor change. Republish when the product, actor, address, warning, language or legal scope changes, and retain the change history.

The canonical record need not be one software system, but it must be controlled. A spreadsheet can hold data; it does not by itself establish ownership, evidence, versioning or channel synchronisation.

Common mistakes

Showing the brand instead of the manufacturer

The familiar logo may not identify the legal manufacturer. Publish the actor required by Article 19 and preserve the legal name or registered trade name/mark accurately.

Omitting one of the two address types

Article 19 requires both postal and electronic addresses for the manufacturer and, where applicable, the responsible person. A postal address alone or a homepage with no direct communication route is insufficient.

Replacing the manufacturer with the EU responsible person

For a non-EU manufacturer, both sets of information appear. The responsible person does not erase the manufacturer from the offer.

Calling every EU contact an authorised representative

The responsible person may be an importer, authorised representative or fulfilment service provider in the circumstances set by law. Record the actual capacity and basis.

Treating GTIN as the whole identification requirement

A GTIN can be useful, but Article 19 also names the product picture and type. The offer must allow identification of the actual product and variant.

Leaving warnings on the physical packaging

The applicable warnings and safety information must appear clearly and visibly in the distance-sale offer. Consumers need them before purchase.

Copying all instructions into a “GPSR” field

Article 19(d) concerns warnings and safety information required under the applicable law. Determine what applies; do not invent a universal content dump.

Assuming marketplace approval proves compliance

A marketplace validates its fields and policies, not the entirety of the product's legal status. Conversely, a platform rejection may be a commercial data gate rather than an Article 19 defect.

Direct questions

What must an EU product page show under GPSR?

For a covered distance-sale offer, Article 19 requires manufacturer identity and postal/electronic addresses; the EU responsible person's corresponding information when the manufacturer is outside the EU; product-identification information including a picture, type and other identifier; and applicable warnings or safety information in an easily understood destination-market language.

Does GPSR require manufacturer contact details online?

Yes. The offer must show the manufacturer's postal and electronic address as well as its name, registered trade name or registered trade mark.

What if the manufacturer is outside the EU?

Show the non-EU manufacturer's required information and the name, postal address and electronic address of the responsible person established in the EU. Verify who fills that role for the product.

Does the EU responsible person need to appear on the listing?

Yes, when the manufacturer is not established in the EU. Article 19(b) requires the responsible person's name and postal and electronic address in the offer.

Does GPSR require a GTIN?

Article 19 does not name GTIN. It requires information allowing product identification, including a picture, the product type and any other product identifier. A GTIN may be part of an implementation but is not the only possible identifier and does not replace the other elements.

Must warnings appear on the online product page?

Applicable warnings and safety information that the law requires on the product, packaging or accompanying document must also be clearly and visibly indicated in the distance-sale offer. Use a language consumers can easily understand as determined by the destination Member State.

Does GPSR apply to marketplaces?

Article 19 applies to covered offers made online. Article 22(9) separately requires online-marketplace providers to design their interfaces so traders can provide the information and consumers can see or easily access it. The precise responsibilities of the trader, economic operators and platform remain distinct.

Does Article 19 apply to every product?

No. Determine whether the product and offer fall within the GPSR and how product-specific EU safety law applies. Article 19 is not a universal field list for every item sold in Europe.

Sources

Primary and official sources checked on 1 September 2026:

• Regulation (EU) 2023/988, Official Journal text, especially Articles 2, 4, 9, 16, 19 and 22

  View official source

• Consolidated Regulation (EU) 2023/988, current version dated 29 May 2026

  View official source

• Commission Notice C/2025/6233, Guidelines on the application of the EU general product safety legislative framework by businesses

  View official source

• Regulation (EU) 2019/1020, Article 4, tasks of economic operators regarding products subject to certain EU harmonisation legislation: The Commission Notice is official guidance. The Regulation is the primary legal source. Product-specific EU legislation and destination-market rules must be checked for the product concerned.

  View official source

The Commission Notice is official guidance. The Regulation is the primary legal source. Product-specific EU legislation and destination-market rules must be checked for the product concerned.