GPSR Label Requirements: What Must Be on the Product and Packaging (with Examples)

Where GPSR label requirements come from

The GPSR has no single 'labelling' article. The requirements are spread across the obligations of manufacturers, importers and the responsible person:

For most sellers based in China or elsewhere outside the EU, the factory or brand owner is the manufacturer and an EU company acts as authorised representative ('EC-REP') and therefore as the responsible person. The label then carries two blocks: manufacturer and EU Responsible Person. See our EU Responsible Person guide for who can take that role.

Two nuances matter. First, Article 2(1) says that for products covered by EU harmonisation legislation (toys, electrical and radio equipment and other CE-marked products), Chapter III Section 1 of the GPSR (Articles 9–18, including Articles 9, 11 and 16) does not apply; the identity-labelling rules come from the sector law and Article 4 of Regulation 2019/1020 instead. The online-offer duties in Article 19 still apply. Designing one label that covers the GPSR field list and then adding the sector-specific marks is the practical approach. Second, the Commission's 2025 guidelines confirm that the new labelling requirements do not apply to units placed on the market before 13 December 2024 in line with the old directive, assessed unit by unit.

Field-by-field checklist with example values

The example below uses fictional companies for a typical 'Chinese manufacturer + German EC-REP' set-up. Replace every value with your real data.

A compact packaging block could read (the headings are common practice, not prescribed wording):

Manufacturer: Shenzhen Example Technology Co., Ltd., No. 1 Example Road, Nanshan District, Shenzhen 518000, Guangdong, China, [email protected]

EU Responsible Person: EU Rep Example GmbH, Musterstraße 1, 10115 Berlin, Germany, [email protected]

Model: EX-1000 · Batch: 2026-11-A

What counts as an 'electronic address'

Articles 9(6) and 16(3) require an 'electronic address' without defining it. The Commission's business guidelines (C/2025/6233, November 2025; an interpretation, not the law itself) explain that it can be an email address or a dedicated section of your website that enables consumers to contact you directly and easily, and that a website on its own is not sufficient if it does not allow direct communication.

• Best: a monitored email address used for safety and after-sales questions.
• Acceptable: the specific URL of a contact form through which consumers can reach you directly.
• Not enough: a homepage domain or a brochure site with no contact function.
• Phone numbers: not part of the Commission's explanation of an electronic address; add one if you like, but not as a substitute.

Article 9(11) separately requires manufacturers to publish a complaints and accident-reporting channel. The guidelines note it can be the same as the single contact point on the label, so one monitored mailbox can serve both purposes.

When packaging or an accompanying document is allowed

The fallback wording differs between the three blocks:

• Product identifier (Art. 9(5)): on the product unless its size or nature does not allow it.
• Manufacturer and importer details (Arts. 9(6), 11(3)): on the product, or where that is not possible, on the packaging or in an accompanying document.
• Responsible person (Art. 16(3)): product, packaging, parcel or accompanying document, with no order of preference.

The Commission's guidelines say you should be able to justify your choice and that, in principle, only the size of the product, not aesthetics, can justify moving information off the product. Earrings, memory cards or small accessories can reasonably carry the details on packaging or a hang tag; a small appliance with a flat base usually cannot.

Use the 'parcel' option with care. If the Responsible Person appears only on the shipping box, the information disappears as soon as a distributor unpacks and resells the item, and marketplace reviewers look at product and packaging photos. Printing it on the retail packaging is safer.

Language of instructions and warnings

Articles 9(7) and 11(4) require instructions and safety information in a language easily understood by consumers, as determined by the Member State where the product is made available. In practice this usually means the official language(s) of that country; where a country has several, check the national rules.

• Selling the same item in Germany, France, Italy and Spain means German, French, Italian and Spanish warnings and instructions, usually as a multilingual leaflet and multilingual packaging text.
• Names and addresses are identity data and generally do not need translating.
• Article 9(7) exempts products that can be used safely as intended without instructions; the guidelines use knives as an example. Most electronics, children's and household products do not qualify.
• The same language rule applies to the online offer under Article 19(d), and Amazon staff have said on its seller forums that safety images and documents must be in the store's official language(s).

Extra marks required by other EU laws

The GPSR is a safety net. Many categories have their own labelling rules, which apply on top:

Practical printing tips

The GPSR sets no minimum label size or font size; it requires information to be easily visible and legible. What works in practice:

• Mark the product itself where possible: silk-screen, laser engraving, moulded text or a durable sticker. Model and batch usually sit on the rating plate or base.
• One information block on the packaging with manufacturer, Responsible Person and identifiers, so consumers, inspectors and marketplace reviewers find everything in one place.
• Durability: labels must survive transport, storage and use; avoid thermal paper that rubs off. The Batteries Regulation explicitly requires battery labels to be visible, legible and indelible.
• Stickers added later by an importer or representative must not cover legally required information (Art. 11(3)).
• Photograph every side of product and packaging before launch; Amazon asks for images that show the safety information.
• One source of truth: generate packaging artwork and marketplace data from the same master sheet so spellings and addresses never drift apart.

Digital labels and QR codes: Article 21 allows them only in addition

Many sellers would like a QR code to replace printed text and free up packaging space. Article 21 GPSR rules this out: without prejudice to Articles 9(5)–(7), 11(3) and 16(3) and the relevant harmonisation legislation, economic operators may additionally make that information available in digital form through electronic solutions such as QR codes. Digital labels supplement the physical label; they never replace the mandatory information on it.

• Good uses for a QR code: full multilingual manuals, extended safety information, declarations, how-to videos.
• Never only behind a QR code: product identifier, manufacturer details, EU Responsible Person details, and the warnings and instructions that must accompany the product.
• Requirements for the code itself: Article 21 says it must be clearly visible on the product, or on packaging or an accompanying document where that is not possible, and the digital content must be in a language consumers in the Member State easily understand, including accessible formats for persons with disabilities.
• Sector-specific codes are extra: for example, Article 13(6) of the Batteries Regulation requires a QR code on batteries from 18 February 2027, in addition to the other battery labels.

So 'scan the code and you're compliant' is wrong. Print the mandatory information first, then add a QR code for extra material. Not sure which marks apply to you? Take the three-step compliance check, or read what an EU Responsible Person must do.