GPSR Article 19 Online Listing Requirements: 4 Info Blocks
As of 1 September 2026, a product covered by the GPSR and offered to EU consumers online must show four Article 19 information blocks clearly and visibly before purchase: manufacturer details, EU responsible-person details when the manufacturer is outside the EU, product identification, and applicable warnings or safety information.
What changed in this GPSR online-sales guide?
- September 2026: The four Article 19 requirements were converted into an extractable product-offer checklist.
- September 2026: EU-targeting criteria and the distinction between economic-operator duties under Article 19 and marketplace-provider duties under Article 22 were added from the Commission's 2025 guidance.
Does GPSR Article 19 apply to my online offer?
GPSR Article 19 applies when an economic operator offers a covered product online or through another form of distance selling to consumers in the EU. The European Commission's 2025 GPSR business guidance says EU targeting is assessed case by case. Relevant signals include shipping destinations, available languages, payment methods, Member State currencies and an EU domain name.
Merely placing information on a website does not make every worldwide offer subject to Article 19. If the offer directs sales activity to one or more EU Member States, the Article 19 information must be clear and visible in that offer.
A wholesale portal or “B2B only” label is not an automatic inclusion or exclusion test. The GPSR B2B scope guide separates consumer products moving through a business supply chain from genuinely professional-only products unlikely to be used by consumers.
What information must a GPSR product offer show?
The official text of GPSR Article 19 contains four cumulative information groups:
| Article 19 block | What the online or distance-sales offer must show | Pre-publish check |
|---|---|---|
| Manufacturer | Name, registered trade name or registered trademark, plus the postal and electronic address at which the manufacturer can be contacted | The named entity is the legal manufacturer, not merely the seller or fulfilment provider |
| EU responsible person | If the manufacturer is not established in the EU, the responsible person's name, postal address and electronic address | Both manufacturer and responsible-person details are present and match the product records |
| Product identification | A product picture, the product type and another product identifier | The picture and identifier distinguish the exact offered product and its relevant variant |
| Warnings and safety information | Any warnings or safety information required for the product, in a language consumers can easily understand as determined by the Member State of sale | The content is product-specific, visible and available in every required market language |
The four groups are minimum requirements. Product-specific EU legislation can require additional information.
What does a field-by-field Article 19 listing template look like?
This illustrative template shows how the four Article 19 blocks can be assembled in one product offer. Replace every bracketed field and example identifier with verified, product-specific information.
| Listing field | Illustrative text for the product offer | Verify before publishing |
|---|---|---|
| Manufacturer | Manufacturer: [legal name or registered trade name/trademark], [full postal address], [email address or direct-contact web address] | The identity and contact details match the product, packaging and records |
| EU responsible person, if the manufacturer is outside the EU | EU responsible person: [legal name], [full EU postal address], [email address or direct-contact web address] | The named Article 16 operator is established in the EU and covers this product |
| Product identification | Product: Rechargeable desk lamp, model DL-240, SKU DL240-BLK, shown in the product image | The type, identifier and image all refer to the exact offered variant |
| Warnings and safety information | Safety information: [insert every warning or safety statement required for this product in each required market language] | The text follows the product-specific risk evidence and applicable EU rules |
Where should Article 19 information appear?
Article 19 requires the offer itself to indicate the information clearly and visibly. For an e-shop or marketplace listing, the reliable implementation is a readable product-safety or compliance block on each relevant product offer, accessible before the consumer concludes the purchase.
A generic compliance page, a document sent only after purchase or a contact-free company homepage does not replace product-specific information in the offer. A QR code or supporting PDF may provide extra detail, but it should not be treated as the only route to the four Article 19 information groups.
What manufacturer details must the offer include?
The offer must show the manufacturer's name, registered trade name or registered trademark and the postal and electronic address at which the manufacturer can be contacted. The Commission guidance explains that an electronic address can be an email address or a dedicated website section that enables direct contact. A website homepage without a direct communication channel is not sufficient.
Do not substitute the seller's details unless the seller is legally the manufacturer. A business that sells a product under its own name or trademark can be treated as the manufacturer under GPSR Article 13.
When must the EU responsible person appear?
If the manufacturer is not established in the EU, Article 19(b) additionally requires the name, postal address and electronic address of the EU-established responsible person referred to in Article 16. Depending on the supply chain, that responsible economic operator may be an EU importer, a properly mandated authorised representative or, in defined circumstances, a fulfilment service provider.
The Grüner Baum EU GPSR Responsible Person service explains what we verify before accepting a mandate. The responsible-person entry does not replace the manufacturer entry; both must appear for a non-EU manufacturer.
How should the product be identified?
Article 19(c) expressly requires a picture, the product type and another product identifier. A model, reference, SKU, batch reference or another stable identifier may be appropriate if it distinguishes the exact offer. The online information should match the physical product, packaging and technical records.
A generic image or shared identifier across materially different variants weakens traceability and can point the consumer or authority to the wrong product.
Which warnings and languages are required?
Article 19(d) requires any warning or safety information that must be affixed to the product or packaging or included in an accompanying document under the GPSR or applicable EU harmonisation legislation. The information must use a language consumers can easily understand, as determined by the Member State where the product is offered.
Article 19 does not create one warning statement for every product. The required content depends on the product, its risks, the target users and any product-specific EU rules. A generic disclaimer does not replace the manufacturer's risk analysis, instructions or applicable warnings.
Who is responsible: the seller or the online marketplace?
GPSR Article 19 addresses the economic operator that makes the product available through distance sales. GPSR Article 22 separately requires an online marketplace provider to design its interface so traders can submit the same product-safety information and consumers can access it on the listing.
The marketplace provides the fields and product-listing interface; the relevant economic operator remains responsible for the accuracy and completeness of the product information. A marketplace that sells its own branded product can also act as the manufacturer for that product. Our GPSR online marketplace obligations guide covers Article 22 in detail.
Amazon, Etsy and Shopify use different fields, but their layouts do not change the legal information set:
Article 19 pre-publish checklist
Before publishing or updating a product offer, confirm that:
- the manufacturer is correctly identified with postal and electronic contact details;
- a non-EU manufacturer is accompanied by the correct EU responsible-person details;
- the picture, type and identifier describe the exact offered product;
- applicable warnings and safety information are visible in each required market language;
- the listing matches the physical label, packaging and supporting records.
The GPSR technical documentation guide explains the records behind these visible product-offer claims. Article 19 compliance does not replace the manufacturer's safety assessment or technical documentation.
Can Grüner Baum GmbH review an Article 19 product listing?
Grüner Baum GmbH can review product scope and risk assessment, technical documentation, product, manufacturer and responsible-operator details, labelling, applicable warnings and instructions, and Article 19 listing data. Where applicable, Grüner Baum also assesses whether the Article 16 EU Responsible Person route fits the product and supply chain. The GPSR compliance services explain the review scope, and manufacturers or sellers can request a product assessment. The review is not a product certificate and does not guarantee approval, reactivation or acceptance by Amazon, Etsy, Shopify or another marketplace.
Frequently asked questions about GPSR online sales
Must both the manufacturer and EU responsible person appear in the offer?
Yes, when the manufacturer is not established in the EU. Article 19(a) requires the manufacturer's details and Article 19(b) additionally requires the EU responsible person's name, postal address and electronic address.
Are warnings required for every product listing?
Article 19 requires the warnings or safety information applicable to the specific product under the GPSR or relevant EU harmonisation law. The content and required language therefore depend on the product, its risks and the Member State where it is offered.
Is a company website enough as an electronic address?
Not by itself. Commission guidance says a dedicated website section can qualify only when it enables consumers to contact the business directly; a website without a direct communication function is insufficient.
Does Article 19 apply to every website worldwide?
No. An online or distance-sales offer falls within the GPSR when it targets consumers in the EU; shipping areas, languages, payment methods, Member State currencies and EU domain names can indicate that targeting.
Who must supply the Article 19 information: the seller or the marketplace?
The economic operator making the product available through distance sales must provide accurate Article 19 information for its role. Article 22 separately requires an online marketplace provider to supply the interface through which traders enter the information and consumers access it.
Can the four Article 19 information blocks be provided only through a QR code?
No. Article 19 requires the offer itself to indicate the four information blocks clearly and visibly. A QR code can provide supporting detail, but it should not be the only route to the required information before purchase.
Official sources
- Regulation (EU) 2023/988, Articles 4, 13, 19 and 22
- European Commission GPSR business guidance, C/2025/6233
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