GPSR Labelling Requirements & Label Example (2026)
As of 1 September 2026, there is no single universal GPSR label template. For products within the scope of Regulation (EU) 2023/988, Articles 9, 11 and 16 govern physical product information, while Article 19 sets separate requirements for online and other distance-sale offers.
What changed in this guide?
- September 2026: Corrected the placement rules for the product, packaging, parcel and accompanying document.
- September 2026: Added the Article 19 online-offer requirements and separated GPSR duties from product-specific CE marking and pictogram rules.
Is there a mandatory GPSR label template?
No. The GPSR defines required information and permitted locations, but it does not prescribe one label design for every product. The correct block depends on the manufacturer and importer structure, the Article 16 economic operator, the product identifier, the risk assessment, the target countries and any sector-specific legislation.
What information is required on a GPSR label?
GPSR does not describe every required item as a “label.” It requires the following information to be placed on the product or supplied in one of the permitted alternative locations:
- Product identifier: A type, batch or serial number, or another element that identifies the product and is easily visible and legible to consumers.
- Manufacturer details: The manufacturer's name, registered trade name or registered trade mark, postal address and electronic address. A different single contact point must also be identified where applicable.
- Importer details, where applicable: The importer's name or trade mark, postal address and electronic address when an importer places the product on the EU market.
- Article 16 responsible economic operator: The EU-established operator's name or trade mark, postal address and electronic address.
- Instructions and safety information, where needed: Clear information in a language consumers can easily understand, as determined by the Member State where the product is made available.
Warnings and pictograms depend on the product's risks and any applicable sector legislation. GPSR does not create one universal warning-symbol list for every consumer product.
Where must GPSR information appear: product, packaging or document?
GPSR uses different placement rules for different information. Packaging is not a free alternative whenever product marking is inconvenient.
| Required information | When it applies | Permitted placement | GPSR basis |
|---|---|---|---|
| Product type, batch, serial number or another identifier | Products within scope | On the product. Only when the product's size or nature does not allow this: on the packaging or in an accompanying document. | Article 9(5) |
| Manufacturer name or trade mark, postal address and electronic address | Products within scope | On the product. Where product placement is not possible: on the packaging or in an accompanying document. | Article 9(6) |
| Importer name or trade mark, postal address and electronic address | When an importer places the product on the EU market | On the product. Where product placement is not possible: on the packaging or in an accompanying document. An additional label must not obscure manufacturer information required by EU law. | Article 11(3) |
| Responsible economic operator's name or trade mark, postal address and electronic address | Products subject to Article 16(1) | On the product, packaging, parcel or an accompanying document. | Article 16(3) |
| Clear instructions and safety information | When the product cannot be used safely as intended without them | Supplied with the product in a consumer-understood language determined by the Member State. | Articles 9(7) and 11(4) |
| Manufacturer, non-EU manufacturer's responsible person, product identification and applicable warnings | Online or other distance-sale offers | Clearly and visibly in the offer. | Article 19 |
Can a QR code replace physical GPSR information?
No. Article 21 says the information covered by Articles 9(5)–(7), 11(3) and 16(3) may be made available additionally in digital form. A QR code can supplement the information, but it does not remove the applicable product, packaging, parcel or accompanying-document placement rules.
Article 19 is a separate display duty: the required information must be clear and visible in the distance-sale offer. A QR code or downloadable document alone is therefore not a substitute for the visible online information.
When is EU Responsible Person information required?
A product covered by the GPSR may not be placed on the EU market unless there is a responsible economic operator established in the EU for that product. Depending on the supply chain, this role may be fulfilled by an EU manufacturer, importer, authorised representative with an appropriate written mandate, or a fulfilment service provider under the conditions of the applicable rules. It is not always a separate commercial service provider.
For the Article 16 responsible economic operator, the product, packaging, parcel or accompanying document must show the name or registered trade name or trade mark and contact details, including both postal and electronic address.
An EU Responsible Person does not “approve” a product as safe and does not remove the manufacturer's duties. The manufacturer remains responsible for product safety, risk analysis, technical documentation, traceability and applicable instructions and warnings.
What must appear in an online product offer?
GPSR Article 19 requires an online or other distance-sale offer to show at least:
- The manufacturer's name or trade name, postal address and electronic address.
- If the manufacturer is outside the EU, the Article 16 responsible person's name, postal address and electronic address.
- Product identification, including a picture, the product type and another product identifier.
- Applicable warnings or safety information in a language consumers can easily understand, as determined by the relevant Member State.
The information must be clear and visible in the offer. A QR code, downloadable file or physical label alone does not replace Article 19's visible online information. See the detailed GPSR online sales information guide.
Which language must GPSR warnings and instructions use?
GPSR Articles 9(7) and 19(d) require instructions and safety information in a language that consumers can easily understand, as determined by the Member State where the product is made available. This is more precise than saying that every label field must always use one national official language.
Check the target Member State and applicable product legislation before release. Some markets use more than one language, and sector-specific rules may add language requirements.
Does GPSR require CE marking or specific pictograms?
GPSR does not automatically require CE marking for every consumer product. CE marking and category-specific symbols apply only when separate EU harmonisation legislation requires them. Toys, electrical equipment, cosmetics and chemical products can therefore need additional information under their own rules.
A chemical hazard pictogram, for example, comes from chemical classification and labelling rules when those rules apply; it is not a universal GPSR symbol. Product-specific legislation and the GPSR must be assessed together. Use the warning and pictogram guide to separate risk-based warnings from category-specific symbols.
What can an illustrative GPSR information block look like?
The following block is an example of information structure, not a universal legal template:
| Field | Illustrative content | Include when |
|---|---|---|
| Manufacturer | Example Products Ltd · Street, postcode, city, country · compliance@example.com | Products within scope |
| Product identifier | Model ABC-01 · Batch 2026-09-A | Products within scope; use the identifier that links the item to its records |
| Importer | Example EU Importer GmbH · postal address · electronic address | An importer places the product on the EU market |
| Article 16 economic operator | Name or trade mark · postal address · electronic address | Identify the operator responsible for the product; it may already be the EU manufacturer or importer |
| Warnings and instructions | Product-specific wording in the required market language | The risk assessment or applicable product legislation requires them |
The final content and placement depend on the product, its size and nature, the economic operators in the supply chain, the target countries and the product-specific legislation.
What are the most common GPSR labelling mistakes?
- Moving manufacturer information to the packaging without first checking whether product placement is genuinely impossible.
- Omitting the manufacturer's or responsible economic operator's electronic address.
- Using an SKU that does not reliably connect the product to the corresponding technical file or batch record.
- Showing Responsible Person information on the physical package but not in the online offer.
- Treating a generic warning or CE mark as a substitute for a product-specific risk assessment.
- Translating marketing copy but leaving required warnings unavailable in the consumer-understood language.
How should label revisions be recorded?
Each label version should connect to the exact product model, batch or serial identifier, risk analysis, technical documentation and online listing version. Keep the technical documentation available for 10 years after the product is placed on the market, as required by GPSR Article 9(3), and make sure a revision does not break traceability between the physical product and its records.
Frequently asked questions about GPSR labelling requirements
What information is required on a GPSR label?
For products in scope, GPSR Article 9 requires a visible product identifier and the manufacturer's name or trade mark, postal address and electronic address. Applicable importer details, the Article 16 responsible economic operator's contact details, and product-specific instructions or safety information may also be required.
Can GPSR information go on the packaging instead of the product?
Only in the situations allowed by the relevant rule. The product identifier may move to the packaging or an accompanying document when the product's size or nature does not allow product marking; manufacturer and importer details may move there where product placement is not possible.
Must the EU Responsible Person appear in an online listing?
Yes, when the manufacturer is not established in the EU. GPSR Article 19 requires the online offer to show the responsible person's name, postal address and electronic address clearly and visibly.
Which language must GPSR warnings and instructions use?
Instructions and safety information must use a language consumers can easily understand, as determined by the Member State where the product is made available. National and product-specific rules should be checked for each target market.
Can a QR code replace physical GPSR information?
No. GPSR Article 21 permits the information covered by Articles 9(5)–(7), 11(3) and 16(3) to be made available additionally in digital form. It does not remove the applicable product, packaging, parcel or accompanying-document placement rules.
How does Grüner Baum GmbH help?
Grüner Baum GmbH, established in Germany, reviews the information chain across the product, packaging, parcel, instructions and online offer. Where a written mandate is the appropriate Article 16 route, our EU Responsible Person service connects the agreed product scope to the supporting technical records.
You can send the product category, manufacturer location, target EU markets and current label through our assessment request form.
Official sources
- Regulation (EU) 2023/988 — current GPSR text on EUR-Lex
- European Commission guidelines on applying the EU general product safety framework
This content is general information. The exact requirements depend on the product category, the economic operators in the supply chain and the target market.
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