EU GPSR Labelling Requirements: What Manufacturers and Importers Must Know

EU GPSR Labelling Requirements: What Manufacturers and Importers Must Know

The General Product Safety Regulation (GPSR) applies to nearly all consumer products sold in the European Union, including children’s products, furniture, gym equipment, textiles, and more. While many products are subject to additional EU regulations, the GPSR sets essential labeling standards to protect consumers.

Get a template here: GPSR Solutions Product Label Template

General Labelling Requirements

Under Article 9 of the GPSR, manufacturers and importers must provide the following:

  1. Product Identification: Products must display a type, batch, serial number, or another identifier that enables traceability. If impractical, this may appear on packaging or accompanying documentation.
  2. Manufacturer Details: Name, registered trade name or trademark, postal and electronic address must be shown on the product, or if not feasible, on packaging or accompanying documentation.

Warnings, Instructions, and Age Suitability

Article 6 emphasizes that labeling must clearly state:

  • Age Suitability: Appropriate age group for safe use
  • Warnings: Risk and safety warnings relevant to the product
  • Instructions: Clear guidance for safe use and proper disposal

Language Requirements

Under Article 22, warnings and safety information must be provided in the official language(s) of each EU country where the product is sold.

Placement of Labelling Information

Labeling must be placed in this order of priority:

  1. On the Product: Preferred location for traceability and contact details
  2. On the Packaging: If direct marking is not possible
  3. Accompanying Document: Where neither of the above is practical

Responsibility for Compliance

  • Manufacturers: Responsible for labeling their products correctly under GPSR rules
  • Importers: Required to show their name, trade name, or trademark and contact details on the product

Distributors must ensure products they supply comply with GPSR labeling and safety requirements.

Ensuring Correct Labelling

Do not rely solely on suppliers for labeling compliance. Instead:

  • Prepare precise label files with required information
  • Conduct risk assessments to determine necessary warnings
  • Check relevant product standards for guidance on texts and symbols

Choosing the Right Labelling Method

Methods depend on your business model:

  • Branded apparel → Sewn-in labels or hang tags
  • Private label clothing → Hang tags or stickers
  • Online marketplace seller → Product listing plus accompanying document
  • Drop shipping → Online listing plus digital compliance document

Implementing Labeling at Production or Warehouse Level

A. Direct Manufacturer Labeling

  • Require suppliers to print your EU Responsible Person details on labels, tags, or packaging
  • Include labeling requirements in supplier contracts
  • Check pre-production samples for accuracy
  • Conduct random checks to verify labeling

B. Applying Compliance Stickers at Warehouse Level

  • Use pre-printed compliance stickers with the EU Responsible Person’s details
  • Train warehouse staff to apply them properly before dispatch
  • Perform spot checks for consistency

C. Compliance for Online Marketplaces

  • Update product listings to include:
    • Manufacturer details
    • EU Responsible Person details (if manufacturer is outside the EU)
    • Product identifiers (SKU, EAN, model number)
    • Relevant warnings and safety information
  • Provide documentation via email or invoice upon purchase

Digital Compliance Document

Article 19 of the GPSR requires online sellers to display key information such as manufacturer details, EU Responsible Person, product identifiers, and warnings. QR codes alone are not sufficient but can supplement labeling by linking to a full compliance document that includes:

  • Product description and identifiers
  • Manufacturer and importer details
  • EU Responsible Person details
  • Declaration of compliance
  • Overview of technical documentation
  • Warnings and instructions in relevant languages
  • Incident reporting process

Ongoing Compliance & Monitoring

Regular Audits

  • Review labeling and documentation every six months
  • Monitor EU safety regulatory updates

Handling Compliance Requests

  • Ensure documentation is available for authorities on request
  • Inform your EU Responsible Person of any regulatory concerns

Incident Reporting (Article 20)

  • Report serious risks through the EU Safety Business Gateway
  • Online marketplaces must document and escalate safety complaints

Consequences of Non-Compliance

Failure to meet GPSR labeling requirements can result in blocked shipments, recalls, and enforcement actions. Non-compliance may be costly and could prevent products from being placed on the EU market.

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