GPSR in Your Online Shop: The Mandatory Disclosures Every Product Page Has Required Since December 2024

Yes, without exception. Verordnung (EU) 2023/988 contains no exemption based on turnover or business size. Whether you are a wholesaler or a sole trader running an Etsy or Shopify shop: once you offer physical consumer products in the EU, the disclosure obligations under Artikel 19 apply in full. Marketplace sellers on Amazon or eBay are also covered — the platforms tightened their requirements from December 2024 and in some cases automatically block incomplete listings. There is no legal basis for arguing you are "too small for this".

The responsible person is an economic operator established in the EU who can be held accountable for product safety — for example, the importer, an authorised representative, or a fulfilment service provider. Artikel 16 of the GPSR requires that without such a person, the product may not be sold in the EU at all. For classic dropshipping with direct dispatch from China, this is the critical point. If you sell goods without a named EU responsible person, you are placing them on the market unlawfully — even if every other detail is correct. In practice, you must either appoint an authorised representative or source through an EU importer.

No. Artikel 19 GPSR expressly requires the manufacturer details on every individual product listing — that is, on the relevant product page, clearly and prominently. The legal notice does not fulfil this obligation because it does not link the information to a specific product. In practice, the manufacturer's name, trade name, or brand, a postal address, and an electronic contact address must appear in or directly alongside the product description. Many shop platforms now offer a dedicated field for this; anyone who leaves it empty risks a cease-and-desist letter for incomplete mandatory disclosures.

The GPSR acts as a safety net: it applies to all consumer products for which no more specific safety rules exist. Products with their own harmonisation framework — such as toys, electrical appliances, or machinery bearing the CE mark — are primarily subject to their specialist rules, but the GPSR fills any gaps those rules leave. Food, medicines, medical devices, and living plants or animals are excluded. For the typical online shop selling clothing, household goods, cosmetics, décor, or hobby supplies, the default rule is: when in doubt, the GPSR applies. Cosmetics were the most conspicuous category in Safety Gate in 2023, with 1,084 reported dangerous products.

There is no fixed figure, but there is a ballpark: the cost of a competition law cease-and-desist letter depends on the value in dispute. For missing mandatory disclosure infringements, the opposing side's legal fees that you must reimburse typically fall in the range of around €1,000 to €2,000 — per infringement cited, not as a flat fee. On top of that comes a penalty-backed cease-and-desist undertaking: if you repeat the breach, contractual penalties become due. What follows the initial letter is often more expensive than the letter itself, if you do not remedy the situation properly. That is precisely why it pays to check in advance.

In principle, yes. The GPSR also covers used, repaired, or refurbished products, provided they are supplied to consumers in the course of a business. Products that need to be repaired or reconditioned before use and are labelled accordingly are excluded — for example, clearly identifiable parts or items sold for spares. Commercial sellers of second-hand goods should therefore take the safety and manufacturer disclosures just as seriously as for new products. Purely private sales between consumers, however, fall outside the regulation.