How to Write GPSR Safety Information and Instructions: Structure, Warning Examples and Mistakes

What the GPSR actually requires

The GPSR (Regulation (EU) 2023/988) has no single "manual clause". The rules are spread across several articles:

Use the exception carefully. The Commission's business guidelines (C/2025/6233, an interpretation rather than the law itself) give knives, whose risks are well known, as the example. Products that need assembly, run on mains power or batteries, heat up, are meant for children or contain chemicals will almost always need instructions and safety information.

For CE-marked products under Union harmonisation legislation (toys, low-voltage equipment and so on), Article 2(1)(b) disapplies Articles 9 to 18, so the instruction requirements come from the sector law. Article 19 still applies, so the online warnings are still required.

Risk analysis first, warnings second

Recital 22 sets the logic: a high level of safety should be achieved mainly through the design and features of the product, and any remaining risks should be reduced by safeguards such as warnings and instructions. A manual is not a disclaimer. It is an output of your risk analysis.

1. List the hazards from your internal risk analysis: sharp edges, pinch points, tip-over, overheating, battery fire, small parts, suffocation, chemicals. See how to do a GPSR risk assessment.
2. Fix design first. Rounded corners, guards or thermal cut-offs beat a line saying "mind your fingers".
3. Identify residual risks. Only what remains after the design changes goes into warnings and instructions.
4. Think about who will use it. Article 6(1)(e) requires attention to vulnerable consumers such as children, older people and persons with disabilities, and Article 6(1)(f) to products that look like food or appeal to children. If children are likely to get hold of an adult product, warn about it.
5. Cover foreseeable misuse. Safety is judged under normal or reasonably foreseeable conditions of use (Article 3(2)), so common misuse, such as third-party chargers or charging on a bed, deserves a warning.
6. Keep a mapping table of each residual risk, its warning and where it appears, in your technical file. The Commission's technical documentation template even lists "warnings and instructions for use provided with the product comply with European standard [...]" as an example of a risk control measure. See GPSR technical documentation.

A practical manual structure

The GPSR does not prescribe a format. The outline below reflects common practice; adapt it to your product. The international standard IEC/IEEE 82079-1:2019 sets out detailed requirements for writing instructions for use. It is a voluntary reference, not a GPSR presumption-of-conformity standard, unless your product standard calls it up.

For the identity fields and what must be printed on the product itself, see GPSR label requirements; this guide does not repeat them.

How to word a warning, with examples

A useful warning usually has four parts: a signal word (such as "Warning"), the hazard, the consequence and how to avoid it. "Use with care" tells the consumer nothing they can act on.

The wording below is illustrative only. It is not legally prescribed text and does not mean these are the only warnings your product needs. Adapt it to your own risk analysis and check whether sector law or standards fix the wording.

Replace vague parts such as "several minutes" with figures from your own tests or the relevant standard. Watch for cases with fixed requirements:

• Toys: Annex V of the Toy Safety Directive 2009/48/EC fixes the wording of some warnings and requires them to be preceded by "Warning" or "Warnings" in the relevant language. The small-parts example above only shows the structure; on toys use the official wording of the directive and standards in each language. See the toys white paper.
• Electrical and other CE products: harmonised standards often specify warnings that must appear; use the official language versions when translating.
• General consumer products: where a European standard has its reference published in the Official Journal, conformity gives a presumption of safety for the risks it covers (Article 7), so its requirements on warnings and instructions apply as well.

Writing tips: one hazard per warning; active, imperative sentences ("fix it to the wall", not "should be fixed"); consistent terms throughout; the most serious hazard first. Pictograms such as ISO 7010 safety signs help, but pair them with text.

Where each piece goes: product, packaging, manual, listing

The same safety information may need to appear in several places, each with a different job:

How each marketplace collects this information is set out in its own seller help pages, and the wording changes. For the full list of listing fields, see GPSR online selling requirements; for QR codes, see GPSR QR codes and digital labels.

Language, readability and accessibility

The language is set by the country of sale, so selling in several countries normally means several languages. The rules and a translation workflow are in GPSR language requirements for warnings and instructions. A few readability points on top of that:

• Get the source text right. A vague source becomes a vaguer translation. Write short, clear sentences before you send anything to translators.
• Size and contrast. The GPSR sets no minimum font size but requires clear instructions. Light grey micro-print on dark packaging, or text lost in a fold, fails that in practice.
• Match pictures and text. Part numbers in assembly drawings must match the parts list; prohibition symbols need a short explanation.
• Accessibility. Article 21 requires digital information to be available in accessible formats, and Article 9(11) requires complaint channels to take accessibility into account. The Commission's guidelines add that some products fall under the European Accessibility Act (Directive (EU) 2019/882), whose Annex I accessibility requirements then apply to the instructions and safety information. Do not publish a digital manual as a scanned image only; provide text that screen readers can read.

Final checks and record-keeping

1. Check against the risk analysis: every residual risk has a warning or instruction, and every warning traces back to a risk.
2. Check against the product: assemble and use it following the manual; steps, parts and button names must match.
3. Check consistency: product, packaging, manual and listing say the same thing. A listing saying "3+" and a box saying "14+" is a red flag for reviewers and authorities.
4. Version control: give the manual a version number and record which batch each version ships with.
5. File it: keep the final language versions, print proofs and product photos in the technical file, which the manufacturer keeps for 10 years (Article 9(3)). Manuals are among the first documents authorities ask for.
6. Keep improving: manufacturers must investigate safety-related complaints (Article 9(12)). If complaints show consumers misunderstand a step, revise the manual and, where needed, the design.

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