GPSR Labelling Requirements for Non-EU Manufacturers

GPSR labelling requirements have been in force since 13 December 2024, and the six beliefs below are still costing non-EU manufacturers listings, shipments and marketplace accounts. Every one of them sounds reasonable. Every one of them is contradicted by text you can read yourself in about ten minutes.

The rules come from Regulation (EU) 2023/988 on general product safety, adopted 10 May 2023, in force from 12 June 2023 and applicable from 13 December 2024, on which date it repealed the old General Product Safety Directive 2001/95/EC (Regulation (EU) 2023/988, Articles 50 and 52). In November 2025 the Commission added two official interpretive notices, which is where most of the "we were told…" arguments now go to die.

What GPSR labelling requirements actually cover

GPSR labelling requirements are the identification and safety information a product, its packaging and its online listing must carry — not a certification mark, and not a test report. They split into two places.

On the product (Article 9). Manufacturers must ensure their products "bear a type, batch or serial number or other element enabling the identification of the product and which is easily visible and legible for consumers, or, where the size or nature of the product does not allow it, that the required information is provided on the packaging or in a document accompanying the product" (Article 9(5)). Separately they must "indicate their name, their registered trade name or registered trade mark, their postal and electronic address" and place that "on the product or, where that is not possible, on its packaging or in a document accompanying the product" (Article 9(6)). Instructions and safety information must be "in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market" (Article 9(7)).

In the online listing (Article 19). Where products are offered online or through distance sales, "the offer of those products shall clearly and visibly indicate at least the following information":

Article 19 point	What must appear in the offer
(a)	Name, registered trade name or registered trade mark of the manufacturer, plus the postal and electronic address at which they can be contacted
(b)	Where the manufacturer is not established in the Union, the name, postal and electronic address of the responsible person within the meaning of Article 16(1) of the Regulation or Article 4(1) of Regulation (EU) 2019/1020
(c)	Information allowing the identification of the product, including a picture of it, its type and any other product identifier
(d)	Any warning or safety information to be affixed to the product, the packaging or an accompanying document, in a language easily understood by consumers in that Member State

Note point (b): it references Article 4(1) of Regulation (EU) 2019/1020, not Article 16(1) of that regulation. Half the compliance summaries online get this citation wrong, and a wrong article number is how you end up arguing with a marketplace reviewer who has the text open.

Now the myths.

Myth 1: "GPSR only applies if I sell direct to EU consumers"

False, with a real nuance underneath it.

The obligations attach at "making available on the market", which the Regulation defines as "any supply of a product for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge" (Article 3(6)). Selling a container to an EU importer is supply for distribution. Your Article 9 product-marking duties and the Article 16 responsible-person requirement attach the first time that unit is made available on the EU market — through a B2B importer or otherwise.

The nuance: Article 19 (listing information) and Article 22 (marketplace duties) are specifically about distance and online sales. If you never sell online, those two do not bite you directly. Your importer's obligations do, and your importer will push them back up the chain into your PO.

Myth 2: "Our product is CE marked, so GPSR doesn't apply to us"

False, and this is the costliest one.

Article 2(3) does carve out part of GPSR for products covered by EU harmonisation legislation: "Chapter II does not apply insofar as the risks or categories of risks covered by Union harmonisation legislation are concerned" and "Chapter III, Section 1, Chapters V and VII and Chapters IX to XI do not apply."

Read what is not in that list. Chapter III Section 2 — Articles 19 to 21, the distance-sales listing information — is not exempted. Neither is Chapter IV, the online marketplace obligations. The Commission's own November 2025 guidance states it in list form: for products already subject to specific EU harmonisation requirements, "Chapter III Section 2 – economic operator obligations regarding distance sales, reporting on accidents related to products, and the provisions on information in electronic format" is applicable, as is "Chapter IV – providers of online marketplaces" (Commission Notice C/2025/6233, section 2.2).

So a CE-marked toy or appliance is exempt from the GPSR manufacturer marking rules — because its own directive already covers them — and still fully subject to the GPSR listing rules. eBay tells its sellers the same thing in plainer words: "Any CE-marked products that are sold into Europe have to have an EU established economic operator listed on the product or packaging" (eBay, understanding regulations when selling).

Myth 3: "There's a GPSR mark or label format we have to print"

False. There is no GPSR mark. There is no GPSR certificate, no logo, no stamp, no registration number.

Search the full 52-article Regulation and the 41-page Commission guidance for a mandated symbol and you will not find one. GPSR mandates information — manufacturer name and addresses, a type/batch/serial identifier, the responsible person's details, warnings and safety text — placed on the product, its packaging, an accompanying document, or in the online offer. The format is yours to design, provided the result is "easily visible and legible for consumers".

Vendors selling you a "GPSR label template" are selling you a layout, not a compliance requirement. Useful, possibly. Mandatory, no.

Myth 4: "Our UK office can be the EU responsible person"

False for Great Britain. True for Northern Ireland.

Article 16(1) is unambiguous: "A product covered by this Regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020 in respect to that product." Article 16(3) then requires that operator's name and contact details to be "indicated on the product or on its packaging, the parcel or an accompanying document".

The UK government's own publication confirms the split: the Regulation "applies directly in respect of Northern Ireland (NI) from 13 December 2024", and the operator responsible for compliance must be established in the EU or NI (GOV.UK, EU Regulation 2023/988 on general product safety). A London address does not qualify. A Belfast address does.

Who can hold the role is set by Regulation (EU) 2019/1020 Article 4(2): a manufacturer established in the Union, an importer where the manufacturer is not, an authorised representative with a written mandate, or an EU-established fulfilment service provider (Regulation (EU) 2019/1020, Article 4). The Commission guidance puts the consequence bluntly: "you can only place a product on the EU market if there is a responsible person for it established in the EU."

Myth 5: "Our existing stock is grandfathered in"

Mostly false, because the test is per unit, not per product design.

Article 51 does protect what was already sold in: Member States "shall not impede the making available on the market of products covered by Directive 2001/95/EC which are in conformity with that Directive and which were placed on the market before 13 December 2024."

But "placed on the market" means the very first time a specific unit is made available in the Union. The Commission spells this out: "placing on the market means the very first making available of the product on the Union market. This needs to be determined at the level of every specific unit of the product." A new shipment of an unchanged five-year-old product design, arriving in the EU today, is placed on the market today, and complies with GPSR in full or not at all.

While we are here: the guidance also confirms GPSR "applies to products placed or made available on the market whether new, used, repaired or reconditioned", so refurbished and second-hand goods sold by an economic operator are inside the scope too.

Myth 6: "The manufacturer's address has to be on the product photo"

False, and worth getting right because it wastes design hours.

Article 19 requires the information to be indicated "clearly and visibly" in the offer — the listing. It does not require it to be rendered inside the image file. The Commission guidance actually pushes the other way on accessibility grounds, warning that not all information should sit in a picture that cannot be read by text-to-audio software. Required information belongs in listing fields, as real text.

That distinction matters because marketplaces have built exactly that: structured fields. Amazon exposes GPSR attributes in its listings API, including gpsr_manufacturer_reference.gpsr_manufacturer_email_address, dsa_responsible_party_address and gpsr_safety_attestation, with slots for safety documents and their language codes (Amazon SP-API, GPSR listing attributes). eBay's Seller Center lists the same required fields and offers bulk upload of regulatory contacts (eBay Seller Center, General Product Safety Regulation).

Fill the fields. Leave the picture to do the job the picture is good at — which, on a B2B marketplace, is governed by a separate and equally specific rulebook covered in B2B marketplace image requirements.

What actually has to be where

Information	On the product / packaging	In the online offer
Type, batch or serial number (or other identifier)	Yes — Article 9(5), on packaging or accompanying document if the product is too small	Yes, as part of Article 19(c) product identification
Manufacturer name and postal + electronic address	Yes — Article 9(6)	Yes — Article 19(a)
Responsible person in the EU (non-EU manufacturers)	Yes — Article 16(3), on product, packaging, parcel or accompanying document	Yes — Article 19(b)
Warnings and safety information, in the local language	Yes — Article 9(7)	Yes — Article 19(d)
A picture of the product	—	Yes — Article 19(c)
Any GPSR mark or logo	Does not exist	Does not exist

What happens if you get it wrong

Article 44 leaves penalties to national law: Member States "shall lay down the rules on penalties applicable to infringements of this Regulation", those penalties "shall be effective, proportionate and dissuasive", and Member States had to notify the Commission of them by 13 December 2024.

There is therefore no EU-wide fine figure. Any specific euro amount you see quoted is a single Member State's national law, not an EU-level fact — and the practical penalty most exporters actually meet first is not a fine at all. It is a marketplace suppressing the listing. A suppressed listing costs you the same thing a badly-built one does, which is why compliance work and the wider question of professional product images overseas buyers trust tend to land on the same desk in the same week.

Scope: what GPSR does not touch

GPSR is a safety net. Article 2(1) applies it "insofar as there are no specific provisions with the same objective under Union law which regulate the safety of the products concerned". Article 2(2) then excludes medicinal products for human or veterinary use, food, feed, living plants and animals, GMOs in contained use, animal by-products, plant protection products, certain consumer-ridden transport equipment operated by a service provider, aircraft under Regulation (EU) 2018/1139, and antiques.

If your product is not on that list and a consumer can end up using it, assume you are in scope.

Pre-listing checklist

Type, batch or serial identifier is on the product itself — or on the packaging if the product is genuinely too small
Manufacturer name plus both a postal and an electronic address appear on product or packaging
An EU-established (or NI-established) responsible person exists, is named, and is contactable
Responsible person's details appear on the product, packaging, parcel or accompanying document
Warnings and safety information are translated for every Member State you sell into
The same four blocks of Article 19 information are filled into the marketplace's structured fields, as text
A picture of the product is in the offer, per Article 19(c)
Nobody on the team is waiting for a "GPSR certificate" that does not exist

FAQ

When did GPSR come into effect?

Regulation (EU) 2023/988 was adopted on 10 May 2023, entered into force on 12 June 2023 and has applied since 13 December 2024, the same date on which Directive 2001/95/EC was repealed. The Commission published two interpretive notices, C/2025/6233 and C/2025/6238, on 21 November 2025.

Do I need an EU responsible person if I only sell B2B to an importer?

Yes, but your importer will normally be that person. Article 16(1) prohibits placing a product on the EU market at all unless an EU-established economic operator is responsible for it, and Regulation (EU) 2019/1020 Article 4(2) names the importer as one of the four operators who can hold the role. What you must not do is assume the role exists without confirming, in writing, who holds it.

Does GPSR mean I have to redesign all my product images?

No. The legal information belongs in the listing's text fields, not baked into the picture — the Commission guidance specifically discourages locking required information inside an image. What is worth doing is the rest of the job, since you are already rebuilding every listing: the picture still has to answer the question buyers ask most, which is how big the thing is. Marking the actual measured dimensions onto the product image — real measurements snapped to the object's edges, then exported at each marketplace's spec size — is the part of the listing rebuild that pays for itself, and it is a different exercise from generating a nice-looking image with invented numbers on it. The furniture listing annotation example shows what the finished version looks like.

Is CE marking enough for GPSR compliance?

No. CE marking exempts you from GPSR's Chapter III Section 1 manufacturer marking rules, because the relevant harmonisation legislation already covers them. It does not exempt you from Chapter III Section 2 — the Article 19 distance-sales listing information — or from Chapter IV, the marketplace obligations. The Commission's 2025 guidance lists both as applicable to harmonised products.

What are the fines for GPSR non-compliance?

There is no EU-wide figure. Article 44 requires each Member State to set penalties that are "effective, proportionate and dissuasive" and to have notified them to the Commission by 13 December 2024. Any specific amount quoted online is national law from one country and should be checked against that country's own source.

Does GPSR apply to used and refurbished goods?

Yes. The Commission guidance states that GPSR applies to products "whether new, used, repaired or reconditioned", and that the obligations apply fully to second-hand, refurbished and reconditioned products placed or made available on the market by an economic operator. Repairs a consumer does to their own item are outside it.

GPSR Labelling Requirements: 6 Myths Exporters Still Believe