Required product information under GPSR
GPSR Article 19 lists the information online sellers must surface before checkout — manufacturer details, Responsible Person, identifiers, warnings, safe-use instructions. Here is what each field really means in practice.
Of all the new obligations GPSR introduced, Article 19 is the one that bites every online seller every day. It lists the information that must appear on the product listing before the consumer can complete the purchase, and it is the single most common reason listings are suppressed by marketplaces or flagged by national authorities.
This guide walks through each Article 19 field, what it actually requires, and how to render it on the channels online sellers actually use.
The Article 19 checklist
Article 19(1) of Regulation (EU) 2023/988 requires that the following be made available to the consumer prior to the conclusion of the distance contract — that is, before checkout:
- Manufacturer name, registered trade name or trade mark. The legal name on company registry filings, not a marketing name unless that marketing name is also the trade mark.
- Manufacturer postal and electronic address at which they can be contacted. Single address; PO boxes are not sufficient unless they are the legally registered office.
- For non-EU manufacturers, the EU Responsible Person's name and contact — including the same postal-and-electronic-address pair required of the manufacturer.
- Product identifier. Type, batch or serial number; for serialised products, the serial; for batches, the batch reference; for everything else, a unique model identifier.
- Warnings or safety information affixed to the product or its packaging, reproduced in the listing.
- Instructions for safe use where the product is not self-evidently safe.
The Commission Q&A clarifies that "available" means rendered on the product page, not behind a link the user must click. A specs tab is acceptable if it is open by default on page load.
Field-by-field, what enforcement actually expects
Manufacturer name and contact
National authorities have rejected listings where the manufacturer is shown as a trading-as name without the underlying legal entity. The defensible format is "BrandX, a trading name of LegalEntityCo SAS, 12 rue de l'Industrie, 75001 Paris, France — compliance@brandx.com."
If you private-label products from a third-party factory and put your brand on the goods, you are the manufacturer under Art. 3(8) — list yourself, not the OEM.
Responsible Person (non-EU sellers only)
For non-EU brands this is the entry point auditors check first. The format mirrors the manufacturer block: legal name, EU postal address, monitored email. Many small brands use a third-party Responsible Person service; the service's contact details go in the listing.
A frequent mistake: listing the Responsible Person only on the brand's "Legal" page and not on the product listing. Article 19 is product-specific.
Product identifier
Three acceptable formats:
- Type identifier — e.g. "Model TX-200, variant Black/Medium." Works for consumer electronics and apparel.
- Batch number — e.g. "Batch 2026-04-15-A." Works for personal care, FMCG and short-cycle goods.
- Serial number — for serialised products (mainly electronics, regulated goods).
For most apparel and household products, a stable type identifier per variant SKU is sufficient.
Warnings and safety information
The warnings must be the same warnings as those affixed to the product — you cannot soften them for marketing. For small-parts products (toys and toy-like items), the EN 71-1 small-parts warning must appear; for products with lithium batteries, IATA UN 38.3 warnings; for chemicals, the CLP hazard pictograms in the destination market language.
The 2025 enforcement reports show this is the most common gap: brands transcribe the warning correctly in English but not in French, German, Polish or Spanish for those destination markets.
Instructions for safe use
Required where the product is not self-evidently safe. Furniture assembly, electrical installation, age-appropriate use guidance, charging instructions. A link to a downloadable PDF in the destination language is acceptable; an image of the instruction sheet is not (not screen-reader accessible, often unreadable on mobile).
Rendering it cleanly on each channel
Shopify
Use a dedicated compliance.* metafield namespace and a theme block that renders the metafields in a stable order above the buy button. Combine with Shopify Markets visibility rules so the block appears only for EU shoppers. See our Shopify-specific guide for the implementation pattern.
Amazon EU marketplaces
Amazon has integrated GPSR fields into Seller Central since November 2024. Fields populate via the Manufacturer / Responsible Person attribute set in the Manage Inventory flow. Missing fields trigger a soft suppression after the December 2024 grace period ended. See our Amazon-specific guide.
Etsy
Etsy's compliance hub launched in January 2025. EU-resident sellers and non-EU sellers shipping to the EU must complete the GPSR profile per shop. See our Etsy guide.
Your own DTC site
Build a structured compliance component (Liquid section, React component, Webflow embed) that reads from a single data source. Hardcoding the data per product page guarantees it drifts.
How Regonance helps
Regonance reads your existing product feed and supplier files, identifies which Article 19 fields are missing per SKU per channel, and outputs a ready-to-paste compliance block in the destination market language. Run a free scan on a single SKU to see your current Article 19 coverage.
The single most common audit finding
In the BAuA (Germany) and DGCCRF (France) 2025 enforcement summaries, the most common Article 19 finding is the same: manufacturer contact and Responsible Person details present on the website but not on the listing page itself, and not in the destination market language. The fix is structural — render the data from a single source on every product page, in every destination language — not editorial.
Glossary
Article 19. The clause of GPSR that lists the information online sellers must surface before checkout for EU consumers.
Distance contract. A contract concluded without the simultaneous physical presence of trader and consumer; "before the conclusion of the distance contract" effectively means before the checkout button.
Responsible Person. The EU-established person designated under Article 16 to carry out a non-EU manufacturer's GPSR duties.
Type / batch / serial identifier. The three acceptable formats for the product identifier required under Article 19(1)(d).
Educational information, not legal advice. Consult the consolidated text of Regulation (EU) 2023/988 on EUR-Lex for the authoritative legal source.
Frequently asked questions
Where exactly on the listing does Article 19 information have to appear?+
GPSR Article 19(1) requires it to be 'visible to the consumer before the conclusion of the contract.' In practice that means above the buy button on the product page, not buried in a tab the user has to open. Marketplaces have largely interpreted this as a dedicated compliance section on the listing.
Does the information have to be in the buyer's language?+
Warnings and safe-use instructions must be in 'a language easily understood by consumers' in the destination market (Art. 9(7) and Art. 19(1)). Identifiers and contact addresses do not strictly need translation, but most enforcement authorities expect the full set localised. Plan to localise for every EU destination market you ship to.
Can I list the manufacturer once globally and skip it on each product page?+
No. Article 19 is product-specific because the manufacturer can differ between SKUs (private-label, multi-brand catalogues). A sitewide 'about' page is not sufficient — the data has to render on the product page itself.
What format must the Responsible Person contact take?+
Article 16(3) requires both a postal address inside the EU and a monitored electronic address — typically an email or a contact-form URL. Toll-free phone numbers are not sufficient on their own. The contact must accept communications in at least one EU official language.
What counts as a 'warning' for an everyday consumer product?+
Any hazard a reasonable consumer needs to know to use the product safely — choking hazards on small parts, age suitability, allergens, electrical safety, chemical content, charging instructions for lithium batteries. Article 9(7) requires warnings to be 'clearly visible and legible' and in the destination language.
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