GPSR Article 19 on Shopify product pages
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Short answer
The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024. Article 19 says that when products are sold online, "the offer of those products shall clearly and visibly indicate" four groups of information. These are: the manufacturer and its postal and electronic address; the EU responsible person, if the manufacturer is not established in the EU; information that identifies the product (a picture, its type and any other identifier); and warnings or safety information in a language consumers in that Member State can easily understand. For a Shopify store, the "offer" is in practice the product page. The duty applies to economic operators, which includes retailers (distributors) as well as brands.
What exactly does Article 19 require?
Article 19 ("Obligations of economic operators in the case of distance sales") lists the minimum information for each offer:
- (a) "name, registered trade name or registered trade mark of the manufacturer, as well as the postal and electronic address at which they can be contacted";
- (b) "where the manufacturer is not established in the Union, the name, postal and electronic address of the responsible person within the meaning of Article 16(1) of this Regulation or Article 4(1) of Regulation (EU) 2019/1020";
- (c) "information allowing the identification of the product, including a picture of it, its type and any other product identifier";
- (d) "any warning or safety information to be affixed to the product or to the packaging or included in an accompanying document in accordance with this Regulation or the applicable Union harmonisation legislation in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market".
Article 19 sets a minimum ("at least"). Sector rules, such as those for toys, cosmetics or electrical equipment, can add more.
Who is the "responsible person"?
Article 16(1) GPSR says a product may not be placed on the EU market unless an economic operator established in the Union is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020. Article 16(1) applies Article 4(2) of that regulation, so the responsible person is one of:
- a manufacturer established in the EU;
- an importer, where the manufacturer is not established in the EU;
- an authorised representative with a written mandate from the manufacturer;
- a fulfilment service provider established in the EU, for the products it handles, where none of the above is established in the EU.
Their tasks include cooperating with market surveillance authorities, informing them of risks and providing documents on request. Article 16(3) also requires their name and contact details on the product, packaging, parcel or an accompanying document. That is physical labelling, separate from the product page.
If you sell your own brand made in the EU, (a) and (b) usually point to the same company. If you resell products made outside the EU, ask your supplier who the EU responsible person is before you list the product.
Which dates apply?
| Date | What happens | Source |
|---|---|---|
| 23 May 2023 | Regulation (EU) 2023/988 published in the Official Journal | EUR-Lex |
| 12 June 2023 | Entry into force (20th day after publication, Article 52) | EUR-Lex |
| 13 December 2024 | The regulation applies (Article 52); it replaces Directive 2001/95/EC | EUR-Lex |
As a regulation, the GPSR applies directly in every Member State. National law adds enforcement, penalties and, for point (d), which languages count.
What should a Shopify product page show?
A practical layout for each product page:
| Article 19 point | What to show | Where it usually lives in Shopify |
|---|---|---|
| (a) Manufacturer | Name or trade mark, full postal address, email or contact form URL | Product metafields or metaobjects, shown by a theme block |
| (b) EU responsible person | Name, postal and electronic address (only if the manufacturer is outside the EU) | Same as above |
| (c) Identification | Product picture, type or model, other identifiers (SKU, GTIN, batch or serial number) | Product media, variant SKU and barcode, metafields |
| (d) Warnings and safety information | The text from the label, packaging or instructions | Product description or a dedicated block, translated per market |
Points to keep in mind:
- "Clearly and visibly". The information should be easy to find on the offer. A hidden tab that shoppers cannot open on mobile is a weak choice.
- Per variant. If variants come from different manufacturers or have different warnings, the information should follow the variant.
- Documents. Instructions and safety sheets can be linked as files on the product page. Separately, Article 21 lets operators additionally provide the information required on the product or packaging in a digital format, for example through a QR code on the product. It does not replace that information.
Which languages do I need?
Point (d) requires warnings and safety information "in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market". Each country decides which languages are acceptable, usually its official language or languages. If you sell to Germany, France and Poland, check what each requires. Then make sure the warning is published in a storefront language shoppers in that market actually see. A translation saved in Shopify for a language you have not published will not reach shoppers.
Points (a) to (c) are names, addresses and identifiers, which usually need no translation; translated field labels still help shoppers.
What does Article 19 not cover?
- Product safety itself. Article 19 is about information on the offer. Safety assessment, technical documentation and the duties of manufacturers (Article 9), importers (Article 11) and distributors (Article 12) are separate obligations.
- Excluded products. Article 2(2) excludes, among others, medicinal products, food, feed, living plants and animals, plant protection products and antiques.
- Accidents and recalls. Article 20 requires the manufacturer to notify accidents through the Safety Business Gateway. Importers and distributors must inform the manufacturer.
- Marketplaces. Article 22 sets extra duties for providers of online marketplaces, defined in Article 3 as intermediary services that let consumers conclude distance contracts with traders. A store that sells only its own stock is normally the trader, not the marketplace. If you also sell on marketplaces, Article 22(9) means they will ask you for the same four groups of information.
What to check in your store
- List the EU countries you sell to, and the languages each one requires for warnings.
- For every product, record the manufacturer's name, postal address and electronic address.
- For products made outside the EU, record the EU responsible person and confirm their role with your supplier.
- Check that each product has a picture and a type or model identifier, plus SKU, GTIN or batch where you have them.
- Copy warnings and safety information from the label, packaging or instructions into the product page.
- Translate warnings into each required language and publish those languages on your storefront.
- Check the information is visible on mobile and for each variant.
- Set up a way to record accidents and recalls and reach your manufacturer quickly.
- Ask your legal advisor about sector rules for your product categories.
How Lektoro helps (and what it doesn't do)
Lektoro: GPSR Safety Info is a Shopify app for preparing and checking the information Article 19 lists.
What it does:
- Audits every product per EU target market for missing Article 19 details: manufacturer, EU responsible person, picture, type identifier and warnings in that market's language. It counts only languages published on your storefront.
- Keeps manufacturers and EU responsible persons in one directory and checks that a responsible person is established in the EU.
- Assigns operators, warnings and documents to many products at once, with a preview.
- Tracks translations of warnings and flags them when the source text changes.
- When you choose to publish, shows the details in a "Product safety information" theme block, with labels in all 24 official EU languages.
- Keeps an incident and recall register with an evidence export.
What it doesn't do:
- It does not assess whether a product is safe and does not cover sector-specific rules or labelling on the product itself.
- It does not translate warnings for you. You add each translation.
- It does not notify authorities. It reminds you to check your notification duties.
- It covers the 27 EU Member States. EEA countries outside the EU and Northern Ireland are not supported as target markets yet.
- It writes nothing to your store until you click Publish to storefront.
To see which Article 19 details a store's product pages already show as text, try the free GPSR product page checker. It reads up to 5 public product pages and does not judge whether the details are correct.
Sources
- Regulation (EU) 2023/988 (GPSR), OJ L 135, 23.5.2023: Articles 2, 9, 16, 19, 20, 21, 22 and 52 — https://eur-lex.europa.eu/eli/reg/2023/988/oj/eng
- Regulation (EU) 2019/1020, Article 4 — https://eur-lex.europa.eu/eli/reg/2019/1020/oj/eng
- European Commission, Product safety (obligations for businesses) — https://commission.europa.eu/business-economy-euro/doing-business-eu/eu-product-safety-and-labelling/product-safety_en
Not legal advice. This guide summarises the information duties in Article 19 GPSR as of the date above. It does not cover sector-specific legislation or national rules on languages and penalties. Ask a qualified legal advisor about your products and markets.