GPSR safety warnings: what to write and where it goes

What the GPSR requires, and what it leaves open

Article 9(7) GPSR (opens in a new tab) obliges manufacturers to ensure that their product is accompanied by clear instructions and safety information in a language consumers can easily understand, as determined by the member state where it is sold. Importers ensure the same (Article 11(4)), and the Responsible Person checks it regularly where the risks call for it (Article 16(2)(b)).

The GPSR prescribes no wording, symbols or list of mandatory warnings for general consumer products. Article 6(1)(d) names “any warnings and instructions for its safe use and disposal” as one aspect of the safety assessment.

Derive GPSR safety warnings from the risk analysis

Recital 22 GPSR sets the order: safety should come primarily from design, and warnings and instructions alleviate the remaining risks. A warning is the last measure, never the first:

1. 1.Take every hazard from your GPSR risk assessment, including foreseeable misuse and vulnerable users (Article 6(1)(e) and (f)).
2. 2.Remove or reduce it by design first.
3. 3.For what remains, ask whether users can avoid it by their behavior. Only then can a warning work.
4. 4.Check whether the standard you apply or sector law prescribes a warning.
5. 5.Record each warning next to its risk in the technical documentation (Article 9(2)(a)).
6. 6.Place it where users need it and repeat it in every online offer (Article 19(d)).

Step 3 decides: the Commission's risk guidelines note that warnings may not be fully effective and that young children put things in their mouths (Implementing Decision (EU) 2019/417, Appendix 6, section 3.3). A decorative resin fruit that looks edible (Article 6(1)(f)(i)) needs a different design, not a label a toddler cannot read.

What a clear warning contains: hazard, consequence, avoidance

The GPSR sets no format. Sector law is more explicit: for toys, labels and instructions must draw attention to “the inherent hazards and risks of harm” and to “the ways of avoiding such hazards and risks” (Article 10(2) of Directive 2009/48/EC). We recommend the same three parts for every warning:

• Hazard: what the danger is (“Fingers can be trapped in the hinge”).
• Consequence, where it is not obvious (“The stool can tip and you can fall”).
• Avoidance: what to do or not to do (“Keep hands clear when folding”).

This is our recommendation, not a legal format. Add a signal word where the law requires one; toy warnings are preceded by “Warning” or “Warnings” (Article 11(2)).

Where warnings go: product, packaging, manual and online offer

Article 9(7) GPSR only requires the information to accompany the product; which warnings go on the product or its packaging is your decision (guidelines, point 3.1.1). A workable split:

Gaps show first in the online offer: Article 19(d) requires the offer itself to indicate the warnings. Addresses are covered in GPSR label requirements, manuals in clear instructions under GPSR.

Language: each member state decides, Germany requires German

The GPSR names no language. Articles 9(7), 19(d) and 21 leave it to the member state where the product is made available. Neither “English is enough” nor “all EU languages on every box” follows from the Regulation.

Germany requires German under § 6 ProdSG (opens in a new tab) for instructions and safety information (Articles 9(7) and 11(4) GPSR), warnings in online offers (Article 19(d)) and further information under Articles 21 and 22(9)(d). Missing German instructions, safety information or listing warnings are administrative offences (§ 28(2) nos. 6 and 26 ProdSG; see GPSR penalties).

Language is a safety matter: consumers can become vulnerable when warnings are in a foreign language they do not understand (Implementing Decision (EU) 2019/417, Appendix 6, section 3.3). Check every other target country before you ship.

When a product needs no warnings

Article 9(7) does not apply where the product can be used safely and as intended by the manufacturer without instructions and safety information. The guidelines name products that pose risks well known to consumers, such as knives (points 3.1.1 and 3.1.3).

We read the exception narrowly; record your reasoning in the technical documentation. Extra warnings do not help either: the Toy Safety Directive prohibits its specific warnings where they conflict with the intended use (Article 11(1)), so a rattle made for babies may not say “Not suitable for children under 36 months”.

Sector law comes first: fixed wording for toys

For products under EU harmonization legislation, such as toys or electrical equipment, Article 9 GPSR does not apply and the sector act governs warnings (Article 2(1)(b) GPSR, guidelines point 2.2). Article 19 GPSR still applies, so these warnings also belong in the online offer.

Annex V to Directive 2009/48/EC lists warnings by toy category, and points 2 to 10 of Part B must be used as worded (Article 11(1)). Two examples: activity toys carry “Only for domestic use.”, functional toys “To be used under the direct supervision of an adult.” For the under-36-months warning, the wording is only an example, but it must come with a brief note on the specific hazard (Part B, point 1).

The Toy Safety Regulation (EU) 2025/2509 repeals the Directive with effect from 1 August 2030 (Articles 56 and 59); until then, toys placed on the market must meet the Directive.

Practical example: warnings for a step stool and a pull-up bar

A U.S. home goods brand sells a folding step stool and a door-frame pull-up bar to German consumers through its own online shop. No harmonization legislation applies, so Article 9(7) GPSR applies in full. Its EU Authorized Representative acts as Responsible Person.

Design came first: a lock stops the stool from folding by accident. All texts are in German (§ 6 ProdSG) and linked to their risks in the technical documentation. The Responsible Person regularly checks compliance with Article 9(7) and shows evidence on request (Article 16(2) GPSR).

Common mistakes with warnings

• Warnings copied from a competitor, with no risk behind them in your file.
• A warning instead of a design change for hazards users cannot avoid (Article 6(1)(f)).
• Warnings on the box but not in the online offer (Article 19(d)).
• Safety information only behind a QR code (Article 21).

Conclusion: every warning needs a reason and a place

Good GPSR safety warnings name the risk and what to do about it, in the right language, on the product and in the offer.

The wording remains your responsibility as manufacturer. As your GPSR Responsible Person, Representa reviews labeling, packaging and manuals and keeps your compliance files ready for inspections. Our compliance consulting reviews your documentation and prioritizes fixes. For the file itself, see GPSR technical documentation.

Frequently asked questions