GPSR Article 19 Online Listing Requirements: 4 Info Blocks
A product covered by the GPSR and offered to EU consumers online must show four information blocks clearly and visibly before purchase. GPSR Article 19 lists them: manufacturer details, EU responsible-person details when the manufacturer is outside the EU, product identification, and applicable warnings or safety information.
Do these rules apply to my online offer?
The rules apply when you offer a covered product to consumers in the EU online or through another form of distance selling. The European Commission's 2025 GPSR business guidance says EU targeting is assessed case by case. Typical signals are shipping destinations, available languages, payment methods, Member State currencies and an EU domain name.
Putting information on a website does not bring every worldwide offer under these rules. But if your offer directs sales to one or more EU Member States, the required information must be clear and visible in that offer.
A wholesale portal or a “B2B only” label does not automatically put a product in or out of scope. 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 GPSR text lists four information groups. You must show all four:
| Information 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 |
These four groups are the minimum. Product-specific EU laws can require more information.
What does a field-by-field listing template look like?
This illustrative template shows how to put the four blocks into 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 responsible person 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 the information appear?
The rules require the offer itself to show the information clearly and visibly. For an e-shop or a marketplace listing, the reliable way is a readable product-safety or compliance block on each relevant product offer. Consumers must be able to see it before they complete the purchase.
A generic compliance page, a document sent only after purchase or a company homepage without contact options 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 information groups.
What manufacturer details must the offer include?
Show the manufacturer's name, registered trade name or registered trademark, plus the postal and electronic address where the manufacturer can be contacted. The Commission guidance explains that an electronic address can be an email address or a dedicated website section that allows direct contact. A homepage without a direct communication channel is not enough.
Do not put the seller's details in place of the manufacturer's unless the seller is legally the manufacturer. If you sell a product under your own name or trademark, the GPSR can treat you as the manufacturer.
When must the EU responsible person appear?
If the manufacturer is not established in the EU, the offer must also show the name, postal address and electronic address of the EU responsible person. Depending on the supply chain, this responsible economic operator can 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. For a non-EU manufacturer, both must appear.
How should the product be identified?
The rules expressly require a picture, the product type and another product identifier. A model, reference, SKU, batch reference or another stable identifier can work if it distinguishes the exact offer. The online information should match the physical product, packaging and technical records.
A generic image, or one identifier shared across materially different variants, weakens traceability. It can point the consumer or the authority to the wrong product.
Which warnings and languages are required?
You must show every warning or safety information that the GPSR or other applicable EU harmonisation law requires on the product, on the packaging or in an accompanying document. Use a language consumers can easily understand, as set by the Member State where you offer the product.
There is no single warning text for every product. The required content depends on the product, its risks, its 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?
The listing rules address the economic operator that sells the product online or through other distance sales. The GPSR separately requires an online marketplace to design its interface so traders can enter the same product-safety information and consumers can see 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 be the manufacturer for that product. Our GPSR online marketplace obligations guide explains the marketplace duties in detail.
Amazon, Etsy and Shopify use different fields, but their layouts do not change the legal information set:
Pre-publish checklist for your product offer
Before you publish or update 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 claims. A complete listing does not replace the manufacturer's safety assessment or technical documentation.
Can Grüner Baum GmbH review my 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 your listing data. Where relevant, we also check whether the 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. It 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. The offer must show the manufacturer's details. It must also show the EU responsible person's name, postal address and electronic address.
Are warnings required for every product listing?
You must show the warnings or safety information that apply to your specific product under the GPSR or other relevant EU product law. The content and the required language therefore depend on the product, its risks and the Member State where you offer it.
Is a company website enough as an electronic address?
Not by itself. Commission guidance says a dedicated website section can qualify only when consumers can contact the business directly there. A website without a direct communication function is not enough.
Do these rules apply to every website worldwide?
No. An online or distance-sales offer falls under the GPSR when it targets consumers in the EU. Shipping areas, languages, payment methods, Member State currencies and EU domain names can show that targeting.
Who must supply the listing information: the seller or the marketplace?
The economic operator that sells the product online must provide accurate information for its role. Separately, an online marketplace must provide the interface where traders enter this information and consumers can see it.
Can the four information blocks be provided only through a QR code?
No. The offer itself must show 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
| Topic | Legal basis | Official text |
|---|---|---|
| When an online offer counts as targeting EU consumers | GPSR, Article 4 | Regulation (EU) 2023/988, Articles 4, 13, 19 and 22 |
| Manufacturer details in the offer | GPSR, Article 19(a) | GPSR text on EUR-Lex |
| EU responsible person in the offer | GPSR, Article 19(b) together with Article 16 | GPSR text on EUR-Lex |
| Product picture, type and identifier | GPSR, Article 19(c) | GPSR text on EUR-Lex |
| Warnings, safety information and language | GPSR, Article 19(d) | GPSR text on EUR-Lex |
| When a seller under its own name or trademark counts as the manufacturer | GPSR, Article 13 | GPSR text on EUR-Lex |
| Duties of online marketplaces | GPSR, Article 22 | GPSR text on EUR-Lex |
| EU targeting signals and what counts as an electronic address | European Commission guidance, C/2025/6233 | European Commission GPSR business guidance, C/2025/6233 |
This guide is general information, not legal advice.
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