GPSR label examples for five product types
9 min read
GPSR label examples for five product types, field by field: what goes on the product, what may go on the box and what your online offer must repeat.
You are about to ship to EU consumers, and your packaging designer asks what exactly goes on the label. The General Product Safety Regulation (EU) 2023/988 (GPSR) lists the fields but shows no sample. Here are GPSR label examples for five product types, with the legal basis for each field and where it may go.
What every GPSR label needs, and where it may go
The GPSR applies in full to consumer products without their own EU safety legislation, such as furniture (Commission guidelines, point 2.2). Articles 9, 11 and 16 GPSR (opens in a new tab) require five fields; which role may use which place is set out in our placement matrix by role.
- Product identifier: a type, batch or serial number or another element, such as a barcode, easily visible and legible for consumers; on the packaging or an accompanying document only where the product's size or nature does not allow it (Article 9(5)).
- Manufacturer: name, registered trade name or registered trade mark, postal and electronic address; on the product, or on the packaging or an accompanying document where that is not possible (Article 9(6)). A homepage alone is no electronic address (guidelines, point 3.1.1).
- Importer, if any: the same details, without covering the manufacturer's label (Article 11(3)).
- Responsible Person: name, postal and electronic address on the product, its packaging, the parcel or an accompanying document (Article 16(3)).
- Instructions and safety information in each country's required language, unless the product can be used safely without them (Article 9(7)).
Example 1: a ceramic plant pot under your own brand
A U.S. home decor brand has plant pots made in China and ships them by mail to EU consumers. Selling under its own brand makes it the manufacturer (Article 13(1) GPSR), so its details go on the label, not the factory's. An Authorized Representative is the Responsible Person.
| Field | On the product | On the box or an insert |
|---|---|---|
| Identifier (Art. 9(5)) | Model and batch number on a base sticker | Same, plus barcode |
| Manufacturer (Art. 9(6)) | Company name, U.S. postal address and support e-mail on that sticker | Optional |
| Responsible Person (Art. 16(3)) | Optional | Name, postal and e-mail address |
| Instructions (Art. 9(7)) | None, if the risk analysis shows safe use without them | None |
If you skip instructions, record why in the technical documentation; the Commission's example is a knife, whose risks consumers know well (guidelines, point 3.1.1).
Example 2: stud earrings too small for a label
A Thai jewelry maker ships stud earrings on a backing card by mail to EU consumers. The earrings cannot carry an address, so the card does. According to the Commission, in principle only the size of the product justifies this, not aesthetics (guidelines, point 3.1.1).
| Field | On the product | On the backing card |
|---|---|---|
| Identifier (Art. 9(5)) | None, too small | Style and batch number |
| Manufacturer (Art. 9(6)) | None, too small | Name, postal and e-mail address |
| Responsible Person (Art. 16(3)) | None | Name, postal and e-mail address |
| Instructions (Art. 9(7)) | None | Only if the risk analysis calls for them |
Example 3: a children's drinking bottle with an EU importer
A Korean brand sells stainless steel bottles for children to a German retailer that imports them. A printed animal alone does not make the bottle a toy, which must be designed or intended for play by children under 14 (Article 2(1) of Directive 2009/48/EC (opens in a new tab)); a detachable play figure could change that (is it a toy?).
Food contact law applies on top; the GPSR still covers the risks it leaves open (recital 11 GPSR), so we apply both. Article 15(1) of Regulation (EC) No 1935/2004 (opens in a new tab) requires instructions for safe use where necessary, the name and address of a manufacturer, processor or seller established in the EU, and labeling for traceability. The words “for food contact” or the glass and fork symbol can be left off articles clearly intended for food (Article 15(2)).
| Field | On the product | On the box or an insert |
|---|---|---|
| Identifier (Art. 9(5) GPSR; Art. 15(1)(d) Reg. 1935/2004) | Model and batch number, laser-marked on the base | Same |
| Manufacturer (Art. 9(6) GPSR) | Company name, Korean postal address and e-mail | Optional |
| Importer and Responsible Person (Art. 11(3), 16(3) GPSR; Art. 15(1)(c) Reg. 1935/2004) | Name, postal and e-mail address | Optional |
| Instructions (Art. 9(7) GPSR; Art. 15(1)(b) Reg. 1935/2004) | None | On the box: use and cleaning, such as temperature limits, in German |
As the importer is known before production, print its line at the factory next to yours and label it with both roles. That one line serves all three rules.
Example 4: a chest of drawers shipped in two boxes
A Vietnamese maker sells a chest of drawers to EU consumers, shipped by a fulfillment service provider in the Netherlands. It mandates an Authorized Representative; otherwise the fulfillment service provider would become Responsible Person by default (Article 4(2)(d) of Regulation (EU) 2019/1020 (opens in a new tab)).
| Field | On the product | On the boxes or in the instructions |
|---|---|---|
| Identifier (Art. 9(5)) | Model and batch on a label in the top drawer | Same on both boxes |
| Manufacturer (Art. 9(6)) | Name, postal and e-mail address on that label | Optional |
| Responsible Person (Art. 16(3)) | On that label (our recommendation) | Otherwise on both boxes or in the instructions |
| Instructions and warnings (Art. 9(7)) | Tip-over warning, if the risk analysis calls for it | Assembly and wall fixing, in each country's required language |
Furniture has no size reason to move details to the box, and boxes are recycled first. For the wording of warnings, see GPSR safety warnings.
Example 5: a USB wall charger with CE marking
A Chinese maker sells a USB wall charger through an EU marketplace. Rated for 100 to 240 volts AC, it falls under the Low Voltage Directive (LVD) 2014/35/EU (opens in a new tab) (Article 1) and the Electromagnetic Compatibility Directive 2014/30/EU, so Articles 9 to 18 GPSR do not apply (Article 2(1)(b) GPSR). The directives set the label; Article 4 of Regulation (EU) 2019/1020 requires an EU business, here an Authorized Representative.
| Field | On the product | On the box or an insert |
|---|---|---|
| CE marking (Art. 17 LVD) | On the charger or its data plate | Only if the charger cannot carry it |
| Identifier (Art. 6(5) LVD) | Model and batch or serial number | Only if size or nature prevents it |
| Manufacturer (Art. 6(6) LVD) | Name and postal address; e-mail optional | Only if the charger cannot carry them |
| Instructions and safety information (Art. 6(7) LVD) | None | Always, in each country's required language |
| EU Authorized Representative (Art. 4(4) Reg. 2019/1020) | Optional | Name and postal address; parcel or document also allowed |
| Output data (Annex II, point 2(a), Reg. 2019/1782) | Output voltage, current and power | Not required |
| Waste equipment marking (Art. 14(4), 15(2) Directive 2012/19/EU; § 9 ElektroG) | Crossed-out wheeled bin and date mark | Bin only in exceptional cases |
The online offer still needs an electronic address: Article 19 GPSR applies to CE products too. As of 5 October 2026, a provisional agreement on COM(2025) 503 (opens in a new tab) would add a “digital contact” to these labels 30 months after entry into force; Parliament's plenary vote was indicatively set for 23 November 2026 (procedure 2025/0133(COD) (opens in a new tab)). WEEE registration (waste electrical and electronic equipment) is a separate duty; see WEEE authorized representative in Germany.
What the online offer must repeat
Whatever the label says, every online offer must show clearly and visibly (Article 19 GPSR):
- the manufacturer's name and postal and electronic address;
- for manufacturers outside the EU, the Responsible Person's name, postal and electronic address;
- a picture, the type and any other product identifier;
- warnings and safety information from the product, packaging or documents, in the language the country of sale requires.
In Germany, listing warnings must be in German (§ 6 ProdSG (opens in a new tab)); other countries are covered in GPSR language requirements.
Common mistakes on GPSR labels
- An EC REP symbol instead of details. It is a symbol from medical device labeling standards, not a GPSR requirement; Article 16(3) asks for name and contact details.
- CE marking on a GPSR-only product, such as the pot or the chest of drawers, which Article 30(2) of Regulation (EC) No 765/2008 (opens in a new tab) forbids.
- A QR code instead of the fields. It may only add to them (Article 21 GPSR).
- An importer sticker over the manufacturer's details, which Article 11(3) GPSR forbids.
Conclusion: one pattern for every product
All five examples share one pattern: identifier and manufacturer on the product unless it is too small, the Responsible Person on the product, box, parcel or a document, the same details in every listing, sector rules on top. Check again whenever the importer, the Responsible Person or the packaging changes.
As your GPSR Responsible Person, Representa reviews and updates labeling, packaging and manuals within the agreed scope and mandate, and our Labels, Manuals & Product Information service checks labels, manuals and online offers before you print. For CE products such as chargers, we can take on the role of your EU Authorized Representative. The label content remains your responsibility as manufacturer.
Frequently asked questions
Is a barcode enough as the GPSR product identifier?
Article 9(5) GPSR asks for a type, batch or serial number or another element that identifies the product and that consumers can easily see and read; the Commission's guidelines name a barcode as an example. We recommend adding model and batch in plain text, because the online offer must also show the product type (Article 19(c)).
Does a GPSR label need the CE marking?
No. CE marking may only be affixed where EU legislation provides for it, such as the Low Voltage Directive for a mains charger (Article 30(2) of Regulation (EC) No 765/2008). A product covered only by the GPSR, such as furniture, must not carry it.
Can a QR code replace the address on a GPSR label?
No. Article 21 GPSR allows the information in digital form, for example through a QR code, only in addition to the details required on the product, its packaging or accompanying documents under Articles 9(5), 9(6), 11(3) and 16(3).
Do I need an EC REP symbol on a GPSR label?
No. The GPSR prescribes no symbol for the Responsible Person. Article 16(3) asks for the name, registered trade name or registered trade mark and contact details, including postal and electronic address. A plain role heading such as “Responsible Person” makes the line easy to find.
Does the GPSR require a country of origin on the label?
No. Articles 9(5), 9(6), 11(3) and 16(3) GPSR do not ask for one. Sector rules can: imported cosmetics, for example, must state their country of origin (Article 19(1)(a) of Regulation (EC) No 1223/2009). Cosmetics have their own Responsible Person and label rules, and Articles 9 to 18 GPSR do not apply to them.
