Since 13 December 2024, every product listing published online must display a set of specific details: the manufacturer and their contact details, the authorised representative established in the EU where the manufacturer is not based there, the details identifying the product, and safety warnings in the consumer’s language. For a distributor, this is not an isolated legal issue: it is a set of details to be obtained from suppliers, stored by reference and disseminated across every channel. Here is what the text requires, and how to incorporate it into a product template.
What Regulation (EU) 2023/988 states
The applicable text is Regulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety. It amends Regulation (EU) No 1025/2012 and Directive (EU) 2020/1828, and repeals Directive 2001/95/EC and Directive 87/357/EEC. Article 52 sets its date of application as 13 December 2024. It is referred to by its English acronym GPSR(General Product Safety Regulation). As it is a regulation, it is directly applicable; in France, Decree No. 2024-1171 of 6 December 2024 amended the Consumer Code accordingly.
It is useful to provide some context before going any further: the GPSR acts as a safety net. Article 2 specifies that it applies insofar as there are no specific provisions in EU law governing the safety of the products concerned and pursuing the same objective. The same article excludes certain categories — medicines, foodstuffs, plant protection products, antiques, amongst others — and covers products thatare new, second-hand, repaired or reconditioned. For distance selling, Article 4 defines the scope: a product offered online is deemed to be made available on the market as soon as the offer is targeted at consumers in the Union.
Who is subject to which obligations
The Regulation allocates obligations according to the role played in the supply chain, and a single company may have several such obligations.
- Manufacturer (Article 9)— technical documentation to be kept available for ten years; type, batch or serial number identifying the product; name and postal and email addresses; instructions and safety information in a language readily understood by consumers in the Member State concerned.
- Importer (Article 11)— verifies that the manufacturer has fulfilled its obligations; affixes its own contact details without obscuring those of the manufacturer; retains a copy of the technical documentation for ten years.
- Distributor (Article 12)— verifies, before making the product available, that the manufacturer and, where applicable, the importer have complied with their obligations regarding identification, contact details and safety information. If this is not the case, the product must not be made available.
- Responsible person (Article 16)— a product may only be placed on the market unless there is an economic operator established in the Union responsible for the tasks referred to in Article 4(3) of Regulation (EU) 2019/1020 for that product.
- Online marketplace provider (Article 22)— single point of contact, registration on the Safety Gate portal, processing of removal orders within two working days, and an interface enabling traders to provide the information referred to in Article 19.
For a distributor selling online, the practical change is this: verification is no longer merely documentary and internal; it becomes public. The information must appear on the offer itself, page by page, channel by channel. And if you market a product under your own name or brand, or if you modify it substantially, Article 13 means you are subject to the manufacturer’s obligations.
The mandatory information under Article 19
Article 19 is central to the subject of a product information sheet. When a business operator makes a product available online or via another means of distance selling, the offer must clearly and visibly state at least the following:
- a) The manufacturer— their name, trading name or registered trade mark, as well as the postal address and email address at which they may be contacted.
- b) The person responsible within the EU— where the manufacturer is not established in the Union: the name, postal address and email address of the person responsible within the meaning of Article 16(1) of the GPSR or Article 4(1) of Regulation (EU) 2019/1020.
- c) Product identification— information enabling the product to be identified, including an image, its type and any other product identifier.
- (d) Warnings and safety information— any warnings or safety information that must be affixed to the product, on the packaging or included in an accompanying document, in a language easily understood by consumers, as determined by the Member State in which the product is made available.
Article 22(9) sets out the same list for marketplaces: these four sections must be displayed, or be easily accessible, at the point where the product is listed. The same information must therefore be present on your e-commerce site and in each of your marketplace feeds. Point (d) carries the most weight: the language depends on the Member State in which the product is made available, so a multi-country catalogue means there are more versions to maintain.
Translating these requirements into a data model
Each point in Article 19 corresponds to a structured attribute, not a sentence tucked away in the product description: an attribute is indexable, verifiable, exportable and translatable.
| Regulatory requirement | PIM attribute | Data source |
|---|---|---|
| Art. 19(a) — manufacturer’s identity | gpsr_fabricant_nom, gpsr_fabricant_adresse, gpsr_fabricant_email | Supplier or brand record, once for all the brand’s product references |
| Art. 19(b) — EU responsible person | gpsr_pr_nom, gpsr_pr_adresse, gpsr_pr_email, gpsr_fabricant_hors_ue | Power of attorney, or your own entity if you are an importer |
| Art. 19(c) — identification and image | gpsr_type_produit, gpsr_numero_lot_serie, media_principal | Supplier technical data sheet, product label, internal digital asset management (DAM) |
| Art. 19(d) — safety warnings | gpsr_avertissements and gpsr_pictogrammes, provided in each language | Instructions, packaging, supplier’s accompanying document |
| Art. 15 — upstream and downstream traceability | fournisseur_id, date_reception, clients_pro_livres | ERP, supplier orders and B2B sales |
| Art. 36 — contents of a recall notice | Image, name, brand, gpsr_numero_lot_serie, distribution history | Attributes already present in the PIM, aggregated at the time of the recall |
Obtain data from suppliers
The details specified in Article 19 cannot be inferred: they must be requested. Include them in the listing questionnaire, in the same way as the purchase price and the EAN, and refuse to create a new listing until the GPSR fields have been completed. Two points are worth noting: the manufacturer’s email address must be genuinely contactable, and the type, batch or serial number must match that shown on the product or its packaging.
Making attributes mandatory by product family
Not all product references are affected in the same way: the categories excluded by Article 2 are not covered, and the warnings depend on the product type. The appropriate level of granularity is therefore the family: link the set of GPSR to it, mark them as required at this level, and let the template propagate the rule to new SKUs. The field gpsr_pr_nom becomes mandatory, for example, as soon as gpsr_fabricant_hors_ue is true — a conditional rule rather than a blanket requirement.
Ensure that no record is published whilst incomplete
A completeness score per family, calculated based on the required GPSR attributes, allows you to block the publication of an incomplete product listing rather than correcting it after it has been flagged. Three checks are worth automating: the presence of a main image, the presence of warnings in each language of publication, and consistency between the shop’s country and the published language.
Pushing data to the channels
The information must appear on the product listing, and therefore in every outgoing feed: e-commerce site, marketplaces, price comparison sites, and Google Merchant Centre feeds. Each channel has its own attribute mapping, and marketplaces have introduced dedicated fields since the regulation came into force. The principle remains the same as for any product data: a value entered once, converted to the channel’s format, and republished when it changes. This is what thePixee PIM Compliance modulemanages, alongside REACH, RoHS, CE and WEEE attributes.
Traceability, incidents and recalls
Three obligations are not visible on the product sheet but are based on the same data. Firstly, traceability: Article 15 requires, upon request from a market surveillance authority, that you identify any economic operator who has supplied the product, a part, a component or embedded software, as well as any economic operator to whom you have supplied it. This information must be available forsix years; information relating to risks and corrective measures must be kept for ten years.
Next, the reporting of accidents: Article 20 requires the manufacturer to report, via the Safety Business Gateway access point and without undue delay, any accident caused by a product that has resulted in death or serious adverse effects on health and safety. The notification must include the type and identification number of the product, as well as the circumstances of the accident. Importers and distributors who become aware of such an accident must inform the manufacturer, who shall then notify the relevant authorities or instruct them to do so.
Finally, the recall: Article 35 requires direct notification of identifiable consumers, using customer data already collected for this purpose; if it is not possible to contact them all, a notice must be widely disseminated (website, social media, newsletters, points of sale). Article 36 sets out the content of this notice: the heading ‘Product recall for safety reasons’, an image, the name and brand, the batch or serial numbers, a description of the hazard without that downplay the risk, the action to be taken, redress options, and a freephone number or online service. Most of these elements already exist within the PIM: a well-prepared recall is, first and foremost, a well-structured catalogue.
What the GPSR does not cover
Three common misunderstandings frequently arise, and they cost the project time.
- The GPSR is neither REACH nor RoHS— it does not cover chemical substances. The SVHC notification, the SCIP database and substance restrictions are governed by separate regulations, detailed in our article on REACH, RoHS, CE and WEEE compliance.
- The GPSR does not create a CE marking— it does not introduce any marking, EU declaration of conformity or assessment by a notified body. These requirements stem from sector-specific harmonisation legislation, which the GPSR supplements without replacing.
- The GPSR is not the Digital Product Passport(DPP) — the DPP stems from the Ecodesign Regulation (EU) 2024/1781 and its category-specific delegated acts. Article 18 of the GPSR merely provides that the Commission may, by delegated act , a traceability system for certain products or categories posing a serious risk. The timeline and scope of the DPP are discussed in our article on the EU Digital Product Passport 2026.
These layers overlap rather than replace one another, as is also the case with the French obligations described in our article on the AGEC Act and the reparability index. Hence the value of a single reference framework: one attribute, one value, multiple regulatory uses.
Frequently asked questions
I am a distributor, not a manufacturer: does this really apply to me?
Yes. Article 12 requires the distributor to verify, before making a product available, that the manufacturer and, where applicable, the importer have fulfilled their obligations regarding identification, contact details and safety information. And Article 19 applies to economic operators in general: it is your online offering that must carry the required information.
What should I do if the manufacturer is outside the EU and there is no responsible person?
Article 16 is clear: a product covered by the Regulation may only be placed on the market if there is an economic operator established in the Union who is responsible for the tasks referred to in Article 4(3) of Regulation (EU) 2019/1020. If you import the product yourself, this role will usually fall to you. Their contact details must appear on the product, its packaging, the consignment or an accompanying document, and on the online offer in accordance with Article 19(b).
Do warnings need to be translated into all languages?
In a language that consumers can easily understand, as determined by the Member State where the product is made available. If you sell in France, Belgium and Spain, you must maintain the corresponding versions — hence the advantage of storing the warnings as a translatable and versioned attribute, rather than as a block of text copied into each shop.
Is a PIM enough to ensure I am compliant?
No, and it is no substitute for a legal analysis: only the official text is authoritative. A PIM handles the data side of things: centralising attributes, making them mandatory by product family, checking for completeness before publication, distributing content across each channel and maintaining the history. Decisions regarding market launch, withdrawal and notification remain yours.
Structure your GPSR attributes once and for all
Compliance attributes per product family, completeness checks before publishing, distribution to every channel.
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