GPSR product information for Shopify stores: what applies since December 2024

What the GPSR covers

On 13 December 2024 the GPSR replaced the former General Product Safety Directive 2001/95/EC (Articles 50 and 52). As a regulation it applies directly in every EU member state, without national implementing laws. It defines when a product is safe, what manufacturers, importers and distributors must do, and how recalls work.

For online sellers, Article 19 is the key provision: it sets out what every distance-selling offer must contain. Penalties for infringements are laid down by the member states and must be “effective, proportionate and dissuasive” (Article 44).

The GPSR applies to products made available on the EU market. If you sell from outside the EU – for example from the US or the UK – to customers in the EU, these rules apply to those offers.

Which products are covered

The GPSR covers products intended for consumers or likely, under reasonably foreseeable conditions, to be used by them (Article 3(1)). That is nearly everything a typical Shopify store sells to private customers: clothing, homeware, toys, electronics, sports and leisure goods. New, used, repaired and reconditioned products are all covered (Article 2(3)).

Article 19 also applies to products with their own EU rules, such as toys or CE-marked electrical equipment. Those products are exempt from some parts of the GPSR (Article 2(1)), but not from the section on distance sales.

Under Article 2(2), the GPSR does not apply to, among others:

• medicinal products for human or veterinary use,
• food and feed,
• live plants and animals,
• plant protection products,
• antiques.

These products are governed by their own rules, often with their own labelling requirements.

The four items required by Article 19

Where economic operators sell products online, Article 19 requires the offer to “clearly and visibly indicate at least the following information”:

1. a
   Manufacturer

   Name, registered trade name or registered trade mark of the manufacturer, and the postal and electronic address at which they can be contacted.

   In practice: usually printed on the product, label or packaging; otherwise ask your supplier. A link to the manufacturer’s website does not replace the postal and electronic address.

2. b
   Responsible person in the EU

   Only where the manufacturer is not established in the EU: name, postal and electronic address of the responsible person under Article 16(1) GPSR or Article 4(1) of Regulation (EU) 2019/1020.

   Who can take on this role is explained in the guide EU responsible person.

3. c
   Product identification

   Information allowing the product to be identified, including a picture of it, its type and any other product identifier.

   In practice: product photo, product type (such as “children’s high chair”), plus model or type number, SKU, EAN/GTIN and, where available, batch or serial number.

4. d
   Warnings and safety information

   Any warnings or safety information that the GPSR or other EU rules require 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.

   In practice: the warnings that already belong to the product, such as “Not suitable for children under 3 years”. For customers in Germany, in German.

“Clearly and visibly”: where the information belongs

Article 19 requires the information in “the offer of those products”. The safest place is therefore the product page itself, near the description and price – not only in the legal notice, the terms and conditions or a single page listing all manufacturers.

Whether a collapsible section is enough has not been settled. A clearly labelled section such as “Product safety” on the product page is common; to avoid any doubt, show it expanded.

Options in Shopify

• In the product description. Works without extra tools but gets messy with many products: when a manufacturer’s address changes, every description has to be edited.
• In metafields. Shopify lets you add custom fields to products, which Online Store 2.0 themes can show through “dynamic sources” in the theme editor. Cleanly separated, but creating and assigning the data remains manual work.
• With an app. Create manufacturers and EU responsible persons once, assign them to many products and show them on the product page with an app block. That is how EuKlar works; its block can be shown collapsed or expanded.

If variants differ in model, EAN or batch, the identifier belongs to the individual variant.

Distributor, importer or manufacturer: your role

Article 19 applies to everyone who sells online. Which other obligations apply depends on your role:

• Distributors (Article 3(11)) sell products that others have manufactured or imported. Before selling, they verify that the manufacturer and importer have met their labelling obligations: type, batch or serial number on the product, contact details, instructions and safety information in the local language (Article 12(1)).
• Importers (Article 3(10)) are established in the EU and place a product from a non-EU country on the EU market – for example if you order goods in China and import them yourself. They also indicate their own name, postal address and email address on the product, its packaging or an accompanying document (Article 11(3)).
• Manufacturers (Article 3(8)) include anyone who has a product designed or manufactured and markets it under their own name or trade mark. If you sell a private label, you therefore have manufacturer obligations: internal risk analysis, technical documentation, kept for ten years (Article 9).

Checklist for your store

1. Review your catalogue

   Which products are sold to consumers, and which fall under an exemption?

2. Record the manufacturer

   Name, postal address and email address – from the product, the packaging or your supplier.

3. Check where the manufacturer is based

   If outside the EU, identify the responsible person in the EU.

4. Record product identifiers

   Product type, model or type number, SKU, EAN and, where available, batch.

5. Copy the warnings

   Everything that must appear on the product, packaging or instructions, in the language of the destination country.

6. Show it on every product page

   In a clearly labelled section near the description and price.

7. Keep it current

   Create new products with complete information and regularly check where something is missing.