Clear instructions under GPSR reduce your liability risk

Why clear instructions matter under GPSR

Manufacturers must ensure that their products are accompanied by clear instructions and safety information in a language that consumers can easily understand, as determined by the member state in which the product is made available. This applies unless the product can be used safely and as intended without them (Art. 9(7) GPSR). The requirement ensures that consumers receive the guidance they need to use products safely and effectively.

For manufacturers outside the EU, the Responsible Person must regularly check that the product meets this requirement (Art. 16(2)(b)).

Compliance and risk prevention

Product instructions play a critical role in risk assessment and mitigation. To comply with GPSR, manufacturers must:

• Conduct a risk assessment of their products: an internal risk analysis before placing them on the market (Art. 9(2)).
• Implement design-based safety measures to reduce hazards (Art. 9(1) and 9(2)(a)).
• Provide clear instructions and warnings to address any remaining risks (Art. 9(7)).

Without proper documentation, companies risk non-compliance, legal liabilities and market restrictions.

Clear instructions and liability

Instructions also matter when something goes wrong. Under the new Product Liability Directive (EU) 2024/2853, which applies to products placed on the market after 9 December 2026, the assessment of whether a product is defective takes all circumstances into account, including its presentation, labeling and instructions for assembly, installation, use and maintenance, and its reasonably foreseeable use (Art. 7(2)).

Clear instructions and warnings therefore reduce the liability risk. They do not exclude liability, and they cannot make up for a product that is unsafe by design.

Paper-first principle: digital comes second

While digital documentation is valuable, GPSR requires the product to be accompanied by instructions and safety information (Art. 9(7)). Manufacturers may provide digital versions in addition, for example through a QR code on the product (Art. 21), but they cannot replace printed safety information.

Key takeaways:

• Physical safety instructions remain mandatory.
• Digital formats are allowed only as an additional resource.
• Documentation must always be accessible in a consumer-friendly format.

Essential GPSR requirements for product instructions

To meet compliance standards, manufacturers must ensure that their product instructions are provided in a language easily understood by consumers in each EU country, as determined by that member state (Art. 9(7)). What else they contain follows from the risk analysis. When assessing safety, GPSR considers among other things the labeling, warnings and instructions for safe use and disposal (Art. 6(1)(d)), the effect on other products, including their interconnection (Art. 6(1)(b)), and cybersecurity features where the nature of the product requires them (Art. 6(1)(g)).

Depending on the product and other applicable laws, such as the rules on electrical waste, batteries or packaging, instructions typically also:

• Include warnings, disposal and recycling information.
• Explain interoperability with other devices when relevant.
• Address cybersecurity risks for connected or smart products.
• Offer repair and maintenance guidelines if consumer repairs are allowed.
• Detail software updates or replacement parts that may impact safety.

Compliance for connected products

With the rise of IoT technology, connected devices need particular attention. GPSR requires the safety assessment to consider appropriate cybersecurity features where external influences, including malicious third parties, could affect the safety of the product (Art. 6(1)(g)), as well as evolving, learning and predictive functionalities (Art. 6(1)(h)).

Specific cybersecurity and privacy requirements come from other acts: Delegated Regulation (EU) 2022/30 under the Radio Equipment Directive, which has applied to many internet-connected radio devices since 1 August 2025, and the Cyber Resilience Act (EU) 2024/2847, which applies from 11 December 2027, with reporting obligations from 11 September 2026. Depending on which of these rules apply, instructions for connected products should cover:

• Cybersecurity protections to prevent unauthorized access.
• Privacy measures to safeguard consumer data.
• Update and maintenance guidelines to ensure ongoing security.
• External risks that could compromise product safety.

Manufacturers in smart technology, wearables and home automation need to integrate cybersecurity considerations into their product documentation.

What defines clear instructions?

A common challenge under GPSR is ensuring that instructions meet the clarity requirement. The voluntary standard EN IEC/IEEE 82079-1 provides structured guidelines for high-quality information for use, including:

• Best practices for clear and accessible information.
• Consistent formatting and structured presentation.
• Standardized evaluation methods for information for use.

GPSR does not make the standard mandatory. Following its guidelines helps manufacturers meet the clarity requirement, minimize liability risks and improve user experience across EU markets.

Compliance as a business opportunity

For companies that see compliance as an opportunity rather than a burden, GPSR offers significant advantages:

• Stronger consumer trust through transparent communication.
• Enhanced brand reputation with clear and professional documentation.
• Reduced product-related risks and liability concerns.
• Long-term market success through seamless compliance.

How Representa helps

At Representa GmbH, we help businesses adapt to these regulatory changes so that their product documentation meets EU requirements and liability risks are minimized:

• Review and update of labeling, packaging and manuals against the GPSR requirements, including the required EU languages.
• Instructions and safety information kept on file as part of the technical documentation.
• Compliance consulting that turns product documentation into a strategic advantage.

By supporting GPSR compliance, we help companies build consumer confidence, secure market access and achieve sustainable growth in the EU.