EU GPSR and Product Listings: What Online Offers and Packs Must Show
The EU General Product Safety Regulation, Regulation (EU) 2023/988 (GPSR), has applied since 13 December 2024. It replaced the 2001 General Product Safety Directive, and GOV.UK guidance says it also applies directly in Northern Ireland. For online sellers it sets two separate groups of duties: what must be printed on or with the product, and what an online offer must show. Neither group requires you to photograph your packaging label.
This guide was checked on 29 October 2026 and is due for review by 29 January 2027. We checked the regulation's text (EUR-Lex did not load in our check, so we read a copy of the Official Journal text), the GOV.UK guidance for Northern Ireland, and the public GPSR pages of bol, Zalando Partner University and Allegro. For Amazon we read a Seller Central Europe announcement; Amazon's detailed help pages and the Commission's November 2025 GPSR guidelines were not publicly readable in our check.
Create listing images from your product photos
Paste your Amazon, Flipkart, Walmart, or Meesho product link or upload phone shots. Picmato recommends listing image templates tailored to your product. Review the plan and choose which images to generate; a nine-image plan does not guarantee nine finished images or nine visible gallery slots. AI renderers do not guarantee an exact RGB value, so check with a color picker before uploading.
What is the EU General Product Safety Regulation (GPSR)?#
The GPSR covers consumer products placed or made available on the EU market. Where other EU law sets safety requirements for a product, the GPSR covers only the aspects and risks that law leaves out. Article 2 excludes, among others, medicines, food, feed, living plants and animals, plant protection products and antiques. It applies to new, used, repaired and reconditioned products.
Article 16 matters most to sellers outside the EU. A product covered by the regulation may be placed on the market only if an economic operator established in the Union is responsible for it, often called the responsible person.
What does Article 19 require in an online listing?#
Article 19 covers distance sales. It is a rule about the content of the listing, not about which photographs you take. The only image it names is a picture that identifies the product, and it does not say the other details must be photographed.
Our working recommendation is to enter the details in the marketplace's text fields, where shoppers can read them on any screen, and to treat pack photographs as supporting material. When you offer a product online, the offer must clearly and visibly indicate at least the following:
- The manufacturer's name, registered trade name or registered trade mark, and a postal and electronic address for contact.
- Where the manufacturer is not established in the EU, the name and postal and electronic address of the responsible person.
- Information that identifies the product, including a picture of it, its type and any other product identifier.
- Any warning or safety information that must be on the product, its packaging or an accompanying document, in a language easily understood by consumers, as determined by the member state where the product is sold.
What must be on the product or its packaging?#
Article 9 sets the physical marking duties for manufacturers, and Article 16 adds the responsible person's details. Identifiers must be easily visible and legible for consumers. The table sets the listing duties beside the product duties.
| Information | In the online offer (Article 19) | On or with the product |
|---|---|---|
| Manufacturer name and postal and electronic address | Required | On the product, or on the packaging or an accompanying document where that is not possible (Article 9) |
| Responsible person in the EU | Required where the manufacturer is outside the EU | On the product, packaging, parcel or an accompanying document (Article 16) |
| Product identification | A picture, the product type and any other identifier | Type, batch or serial number or another identifying element (Article 9) |
| Warnings and safety information | Required where they exist, in a language set by the member state | Instructions and safety information in a language set by the member state, unless not needed for safe use (Article 9) |
What do marketplaces have to do under GPSR?#
Article 22 sets duties for online marketplace providers. Among them, they must act on authority orders about dangerous products within two working days, and design their interface so traders can provide the Article 19 information and it is displayed or easily accessible on the listing.
Traders provide that information and self-certify that they offer only compliant products. The article's text does not require marketplaces to check the accuracy of every detail, and it says nothing about photographing labels. Marketplaces also have Digital Services Act duties, which this guide does not cover. Each marketplace sets its own collection rules:
- bol asks for the manufacturer's name, address and electronic address and the responsible economic operator for each item. Its page says new items without manufacturer details stopped going online from 5 March 2026, and without responsible economic operator details from 1 April 2026.
- Zalando's Partner University page (updated 16 June 2025) asks for manufacturer and responsible person details per brand and identifiers and warnings per article. It does not ask for label photos.
- Amazon announced a Safety and Product Resources section on EU detail pages, separate from product images, and said it would deactivate noncompliant offers.
- Allegro accepts warnings and safety information as text or as PDF, JPG or PNG files, in the official language of the country of sale.
Where can AI image tools fit in a GPSR workflow?#
Picmato can generate lifestyle scenes around your product from packaging photos you upload. It does not check GPSR or any other legal requirement, and it does not verify a translation. The manufacturer details, responsible-person information and warnings a listing must carry belong in the listing's text fields and your own packaging photographs. AI renderers can alter small printed text, so compare every export with the physical pack.
All dimensions, RGB requirements, and technical guidelines in this playbook are verified directly against official 2026 seller portal specifications (Amazon Seller Central, Walmart Marketplace, Flipkart Seller Hub, and FSSAI standards).
Last reviewed for policy compliance: Oct 29, 2026
Frequently asked questions
Does the EU GPSR apply to sellers based outside the European Union?
Yes. The GPSR applies to consumer products placed or made available on the EU market, wherever the seller is based. Article 16 adds that a product may be placed on the market only if an economic operator established in the EU is responsible for it. If the manufacturer is outside the EU, the online offer must also name that responsible person with a postal and electronic address.
What information must a GPSR compliant product listing show?
Article 19 of Regulation (EU) 2023/988 says an online offer must clearly and visibly show the manufacturer's name and postal and electronic address, the EU responsible person's details where the manufacturer is outside the EU, information identifying the product including a picture and its type, and any warnings or safety information in a language consumers easily understand, as set by the member state of sale.
Do I need to photograph my packaging label for GPSR?
The regulation does not require it. Article 19 names one image, a picture that identifies the product, and asks for the other information to be shown clearly in the offer. Marketplaces set their own formats: Zalando's partner guidance does not ask for label photos, while Allegro accepts safety information as text or as PDF, JPG or PNG files. Check the form your marketplace uses.
Can I use English safety warnings across all EU marketplaces?
Not by default. Articles 9 and 19 require instructions, warnings and safety information in a language easily understood by consumers, as determined by the member state where the product is sold. Allegro, for example, asks for attachments in the official language of each country where you sell. Check the language rule for every country before you list there, and translate the warnings themselves, not only the listing.
Does the EU GPSR apply to UK listings?
It depends on where the goods go. GOV.UK guidance says Regulation (EU) 2023/988 has applied directly in respect of Northern Ireland since 13 December 2024. Great Britain, meaning England, Scotland and Wales, is outside the EU regulation and has its own product safety rules. If you sell into Northern Ireland, plan for the GPSR information duties there as well.
Sources & Reference Documentation
- EUR-Lex: Regulation (EU) 2023/988 on general product safety
- GOV.UK: EU Regulation 2023/988 on general product safety (Northern Ireland)
- bol Partner Platform: General Product Safety Regulation
- Zalando Partner University: GPSR-related data requirements
- Amazon Seller Forums (Europe): Manage GPSR compliance with new detail page format
- Allegro: Jakie obowiązki nakłada na Ciebie rozporządzenie GPSR
Recommended Playbooks & Market Guides
Platform policies, image compliance documentation, and conversion frameworks.
Amazon UK Listing Images: Requirements, Product Marks, and Pack Photos
Prepare Amazon UK listing images with clearly scoped size guidance, category-specific CE/UKCA considerations, and accurate product and food pack photographs.
The EU AI Act and E-Commerce: What Online Sellers Need to Know About AI-Generated Product Images
The EU AI Act introduces strict transparency rules for synthetic media. Learn what cross-border e-commerce sellers need to know about AI-enhanced listing photos, labeling, and metadata.
Amazon Listing Image Requirements, Explained
Read Amazon.com image-size guidance, distinguish upload and zoom targets, and prepare accurate main images and galleries with clear source limits.