Why “Clear Instructions” Under GPSR Are Your Best Defense Against Liability
Under the EU GPSR, clear product instructions are a legal requirement. Discover how Representa GmbH helps non-EU manufacturers ensure compliance, minimize liability, and build consumer trust.
The General Product Safety Regulation (EU) 2023/988 (GPSR) has replaced the General Product Safety Directive (GPSD), introducing stricter requirements for product safety, labeling, and consumer information. Under this new regulation, clear, accessible, and well-structured instructions are no longer just a best practice—they are a legal requirement.
At Representa GmbH, we help businesses navigate these regulatory changes, ensuring that product documentation meets EU compliance standards while minimizing liability risks.
Why Clear Instructions Matter Under GPSR
Manufacturers are now legally required to provide comprehensive user instructions and safety information—unless the product can be used safely without them. This mandate ensures that consumers receive the guidance they need to use products safely and effectively.
Compliance and Risk Prevention
Product instructions play a critical role in risk assessment and mitigation. To comply with GPSR, manufacturers must:
Conduct a detailed risk assessment of their products.
Implement design-based safety measures to reduce hazards.
Provide clear instructions and warnings to address any remaining risks.
Without proper documentation, companies risk non-compliance, legal liabilities, and market restrictions.
Paper-First Principle: Digital Comes Second
While digital documentation is valuable, GPSR prioritizes physical instructions to ensure accessibility. Manufacturers may provide digital versions, 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.
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, GPSR introduces additional requirements for digitally connected devices. Instructions must 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 must now integrate cybersecurity considerations into their product documentation.
What Defines “Clear” Instructions?
One of the biggest challenges businesses face under GPSR is ensuring their instructions meet the clarity requirements. The EN IEC/IEEE 82079-1 standard provides structured guidelines for high-quality documentation, including:
Best practices for clear and accessible information.
Consistent formatting and structured presentation.
Standardized evaluation methods for technical documentation.
Following these guidelines helps manufacturers ensure compliance, 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.
At Representa GmbH, we help businesses transform their product documentation into a strategic advantage. By ensuring GPSR compliance, we support companies in building consumer confidence, securing market access, and achieving sustainable growth in the EU.
