GPSR label requirements: which address goes where
9 min readRepresenta GmbH
GPSR label requirements by role: where manufacturer, importer and Responsible Person details go on product, packaging, parcel or listing, with legal basis.
Most guides put every address on a GPSR label into one box. The law does not: the manufacturer's details belong on the product itself, the Responsible Person may also appear on the parcel, and CE-marked products follow their own sector rules. This article sorts the GPSR label requirements by role and place, with the legal basis for each and a label check for a typical product.
Product, packaging, parcel, document: four places with different rules
EU product law distinguishes four places for information that travels with a product: the product itself (rating plate, sewn-in label, engraving), its packaging, meaning the sales packaging, the parcel, and an accompanying document such as the instructions or the Declaration of Conformity. Each role has its own list of permitted places.
The placement matrix: GPSR label requirements by role
Read the table per product: a lamp and a laptop stand from one brand follow different rows.
| Role | Where | Which data | Legal basis |
|---|---|---|---|
| Manufacturer (GPSR product) | Product; if impossible, packaging or accompanying document | Name or trade mark, postal and electronic address, single contact point if different | Art. 9(6) GPSR |
| Product identifier | Product; packaging or document if size or nature prevent it | Type, batch or serial number or similar | Art. 9(5) GPSR |
| Importer, if any | As manufacturer; must not cover the manufacturer's label | Name or trade mark, postal and electronic address | Art. 11(3) GPSR |
| Responsible Person (GPSR product) | Product, packaging, parcel or accompanying document | Name or trade mark, postal and electronic address | Art. 16(3) GPSR |
| Manufacturer and importer (CE product) | Product; if impossible, packaging or accompanying document | Name or trade mark, postal address | e.g. Art. 6(6) and 8(3) Directive 2014/35/EU |
| EU economic operator (CE product) | Product, packaging, parcel or accompanying document | Name or trade mark, contact details including postal address | Art. 4(4) Regulation (EU) 2019/1020 |
| Online offer | The listing, clearly and visibly | Manufacturer, Responsible Person, product identification with picture, warnings | Art. 19 GPSR; Art. 22(9) for marketplaces |
Only the Responsible Person may use the parcel; manufacturer and importer details go on the product whenever possible. Also, CE-marked products follow their sector act, not Articles 9 to 18 GPSR, because Article 2(1)(b) GPSR excludes Chapter III, Section 1 for them. For the acts listed in Article 4(5) of Regulation (EU) 2019/1020 (opens in a new tab), including the low voltage, EMC, radio equipment and toy safety directives, an EU economic operator is added.
The online offer is the exception: Article 19 GPSR sits in Chapter III, Section 2 and applies to CE-marked products too. A lamp's listing therefore needs an electronic address even where its label needs only a postal one. Marketplaces must provide the fields (Article 22(9)); what authorities found missing in 2026 is covered in our article on the GPSR sweep.
When the manufacturer's details may move off the product
Article 9(6) GPSR (opens in a new tab) allows the packaging or an accompanying document only where the product cannot carry the details. The Commission's GPSR guidelines (C/2025/6233) read this narrowly: in principle, only the size of the product justifies the move, not aesthetic or similar reasons, and you should be able to justify your choice in a dispute.
The Blue Guide 2022 takes a similar line for CE-marked products (section 4.2.2.1): aesthetics never count, and hearing aids or sensors are its examples of products too small. It puts the packaging before the instructions and requires a product sold without packaging or documents to carry the details itself.
The product identifier has a slightly wider exception: it may move where the size or nature of the product does not allow it (Article 9(5) GPSR).
Responsible Person: the parcel is allowed, the box is safer
Article 16(3) GPSR lets the Responsible Person's name, registered trade name or registered trade mark and contact details, including postal and electronic address, appear on the product, its packaging, the parcel or an accompanying document. Article 4(4) of Regulation (EU) 2019/1020 allows the same places for CE-marked products, but only the postal address is mandatory.
Legally, a parcel label is enough. In practice it is the weakest option: the parcel is thrown away first and does not follow the product through returns, resale or a repack in a fulfilment warehouse. Print the Responsible Person on the sales packaging. If your importer is also your Responsible Person, the parcel does not help: Article 11(3) GPSR still puts its details on the product where possible.
The manufacturer stays accountable: another operator may add the details, but you must ensure the product is not placed on the market without them (GPSR guidelines). EU distributors verify the labels before selling (Article 12(1) GPSR).
Electronic address and language
Articles 9(6), 11(3), 16(3) and 19 GPSR require an electronic address: according to the Commission, an e-mail address or a website section for direct contact, not a website as such. More in our article on the GPSR guidelines.
Instructions and safety information must be in a language determined by the member state where the product is sold (Articles 9(7) and 11(4) GPSR). Germany requires German, also for warnings in the listing (§ 6 ProdSG). The GPSR sets no language for the address itself, and the Article 4 guidelines add that "manufactured by", "imported by", "represented by" and "fulfilled by" need no translation.
Sector law can be stricter: the Low Voltage Directive requires contact details in a language easily understood by end users and market surveillance authorities (Article 6(6)). According to the Blue Guide, the address need not be translated, but the characters used must allow the company's name and origin to be identified. Check this if your label uses a non-Latin script.
Label check: a U.S. electronics brand with two products
A U.S. electronics brand sells a mains-powered desk lamp and an aluminum laptop stand to EU consumers, shipping directly from the United States. An Authorized Representative whose written mandate covers the tasks of Article 4(3) of Regulation (EU) 2019/1020 is the Responsible Person for both.
- Classify. The lamp falls under the Low Voltage Directive (opens in a new tab), so Article 4 of Regulation (EU) 2019/1020 applies. The stand is a GPSR-only product.
- Name the roles. Manufacturer: the brand. Importer: none, as consumers buy directly. Responsible Person: the Authorized Representative.
- Manufacturer on the product. Lamp: name and postal address (Article 6(6) LVD). Stand: also the electronic address (Article 9(6) GPSR). Both are large enough, so the box is no option.
- Identifier. Type, batch or serial number on each product (Article 9(5) GPSR, Article 6(5) LVD).
- Responsible Person on the sales box, with postal and electronic address. For the lamp only the postal address is mandatory, but the Blue Guide calls an e-mail address useful.
- Language. Instructions and safety information in the language of each target country (Article 9(7) GPSR, Article 6(7) LVD); for the stand in Germany, German (§ 6 ProdSG).
- Listing. Same companies and addresses as on the label, plus picture, model and warnings (Article 19 GPSR).
Common label mistakes
- Addresses without roles. Several companies without roles can mislead authorities; "manufactured by" or "represented by" help.
- An importer sticker over the manufacturer's label. Article 11(3) GPSR forbids it.
- A website instead of a postal address. A web address may be added, not substituted (Blue Guide, section 4.2.2).
- An EC REP symbol instead of details. Article 16(3) GPSR asks for name and contact details, not a symbol.
Conclusion: one matrix per product, checked before shipping
Where an address goes depends on the role and on whether the product is CE-marked. Manufacturer and importer belong on the product, the Responsible Person may also sit on the box or parcel, and the listing repeats both. Check each product before the first shipment.
Representa acts as your GPSR Responsible Person in the EU and reviews labeling, packaging and manuals. For CE-marked products, our CE marking support covers compliant labels and manuals, and we can take on the role of your EU Authorized Representative.
Frequently asked questions
Can the Responsible Person's address be printed only on the shipping box?
Yes. Article 16(3) GPSR and Article 4(4) of Regulation (EU) 2019/1020 allow the product, its packaging, the parcel or an accompanying document. The parcel is the weakest choice because it is discarded first and does not follow returns or repacks, so the sales packaging is safer.
Must the manufacturer's address be on the product itself?
As a rule, yes (Article 9(6) GPSR). The packaging or an accompanying document is allowed only where that is not possible. The Commission's GPSR guidelines say that in principle only the size of the product justifies this, not aesthetic reasons.
Does a CE-marked product need an electronic address on the label?
Not under Article 9(6) GPSR, which does not apply to products covered by harmonisation legislation (Article 2(1)). The Low Voltage Directive, for example, requires a postal address. The online offer must still show an electronic address (Article 19 GPSR).
In which language must GPSR label information be?
Instructions and safety information must be in the language set by the member state where the product is sold (Article 9(7) GPSR); Germany requires German (§ 6 ProdSG). According to the Commission's Article 4 guidelines, role terms such as "manufactured by" need no translation.
May an importer put its own sticker on the product?
Yes. Importers must add their own details, on the product where possible. Their label must not obscure any information required by EU law on the manufacturer's label (Article 11(3) GPSR).