GPSR obligations for online sellers: what belongs in every offer
As of · sourced from primary law · not legal advice · Auf Deutsch lesen
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This English version was prepared with AI from the German page. No native speaker or lawyer has read it. Found a mistake? Write to office@proofpass.eu.
The short answer
The GPSR obligations for online sellers have applied since 13 December 2024, for non-food consumer products, with no volume threshold. Under Article 19 your offer shows the manufacturer’s details, the responsible person where the manufacturer is outside the EU, product identification with a picture, and warning and safety information in the language of the target market.
Art. 16 and 19 GPSR (Regulation (EU) 2023/988)
Who the GPSR applies to
The Regulation covers manufacturers, importers, distributors, fulfilment service providers and providers of online marketplaces. It concerns consumer products that are not food. That includes sales from your own web shop to consumers in the EU.
There is no volume threshold. A seller with a handful of listings has to give the same information.
What belongs in every online offer
Article 19 GPSR sets out what the offer itself has to show. The wording is that the offer “shall clearly and visibly indicate” the information. On the prevailing view among commentators, a bare link or a PDF is not enough for the safety information.
- Manufacturer: name, registered trade name or registered trade mark, plus the postal and electronic address
- Where the manufacturer is not established in the Union: name, 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
- Warning and safety information in a language consumers easily understand, as determined by the Member State where the product is made available
Who must be responsible in the EU
A product may be placed on the market only if an economic operator established in the Union is responsible for it (Article 16 GPSR). The roles follow Article 4 of Regulation (EU) 2019/1020. That operator’s name and contact details go on the product or its packaging, the parcel or an accompanying document. More in the answer on the responsible person.
If you buy from a manufacturer outside the EU, ask who that person is before you list the product.
What marketplaces and courts expect
Amazon keeps manufacturer details per ASIN and safety documents as “Compliance Media”. Offers without the details are marked “Listing removed”. eBay has its own fields for the manufacturer and the EU responsible person and hides non-compliant offers from EU buyers. OTTO, Kaufland, Temu and bol have mandatory fields; at bol, offers without the details have gone offline since 5 March 2026.
According to German legal press reports, the Regional Court of Hechingen held on 23 April 2026 (5 O 37/25 KfH) that a seller is also liable for errors in how the marketplace presents the offer, and that the breach is appreciable under unfair competition law. We have not read the judgment itself. Reported costs of a warning letter (Abmahnung) in Germany run from about EUR 1,380 to 2,000.
What to do, in this order
Work through the range one product line at a time. Start with the products that sell most.
- List every non-food consumer product.
- For each product, establish who the manufacturer is and who is responsible in the EU.
- Get manufacturer details and safety information in the target language from your supplier in writing.
- Enter everything in the offer and in the marketplace fields, not only in your shop system.
- Record what you checked and when.
Frequently asked questions
Does the GPSR apply to very small sellers?
Yes. The GPSR has no volume threshold. It applies to non-food consumer products, including distance sales to consumers in the EU.
Is a PDF with the safety information enough in the offer?
On the prevailing view among commentators, no. The information should be clearly visible in the offer itself. You can offer a PDF in addition.
What happens if details are missing?
Marketplaces take offers offline or hide them. Warning letters and fines come on top. In Germany the amended Product Safety Act (ProdSG) has been in force since February 2026; check the amounts against the text of the law.
With ProofPass
In the product safety module the manufacturer maintains manufacturer details and multilingual safety information once, as text. Distributors and marketplaces get a CSV export. The details also sit on a safety page that a QR code on the product opens. A distributor feed with proof does not exist yet.
The terms and legal notices are in German, and the German version is binding.
Sources
As of 3 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.