Is your listing fit to publish under GPSR Article 19?

What GPSR requires on every listing, explained

The four Article 19 fields look simple, but each has a precise meaning that marketplace compliance scanners and market-surveillance authorities apply literally. Here is what each field actually requires in practice.

Article 19 governs the listing layer only. Physical labelling duties run in parallel: manufacturers must put their name, address and product identifiers on the product or its packaging (Art. 9), and importers add theirs (Art. 11). A complete listing does not cure a bare product, and a fully labelled product still needs the four fields in the online offer.

Sources: Regulation (EU) 2023/988, Arts. 9, 11, 16, 19 (EUR-Lex) · GOV.UK detailed guidance on Regulation 2023/988

Non-EU sellers: the EU responsible person requirement

Under Article 16 of the GPSR, a product manufactured outside the EU may only be placed on the EU market if an economic operator established in the EU is responsible for it. That operator can take one of four shapes: an EU-established manufacturer, an importer, an authorised representative holding a written mandate from the manufacturer, or an EU fulfilment service provider handling the product. For the typical non-EU marketplace seller with no EU importer, the practical route is a paid authorised-representative service.

The responsible person is not a mailbox. Article 16 gives them active duties: verifying that the required technical documentation exists, keeping it at the disposal of market-surveillance authorities, cooperating with those authorities, and informing them when they believe a product is dangerous. Their name, postal address and electronic address must appear both on the product or its packaging and in every distance-sale offer (Art. 19(1)(b)).

Commercial responsible-person services publish prices in the €150–€500 per year range for a low-risk product portfolio — EAS lists plans from €199/year, EUVerify from €200/year, and higher-risk categories such as electronics, toys and cosmetics typically land in the €400–€500 tier. Prices scale with the number of products and the documentation burden. A service that only rents you an EU address without holding your technical file does not discharge the Article 16 duties.

On the listing itself the field reads like: “Responsible Person: [company name], [street, city, EU member state], [email]”. Amazon renders it on the product detail page from the compliance fields you submit in Seller Central; Etsy shows it in the product-safety section of the listing.

Go deeper with two related Seller Guardrails tools: designate your GPSR economic operator · estimate responsible-person service costs

Sources: Regulation (EU) 2023/988, Art. 16 (EUR-Lex) · EAS — GPSR authorised representative (pricing) · EUVerify — authorised representative costs guide

How marketplaces enforce GPSR — Amazon, Etsy, eBay

Marketplace enforcement is not goodwill — Article 22 of the GPSR regulates the platforms themselves. Providers of online marketplaces must register with the EU Safety Gate portal, name a single contact point for authorities, act on official takedown orders without undue delay and in any event within two working days, and design their listing interfaces so sellers can supply the Article 19 information. That is why every major platform has built structured compliance fields and automated suppression around them.

Beyond the marketplace: national penalties

Marketplace suppression is only the first layer. National authorities enforce the regulation with penalties each member state sets itself — Article 44 requires them to be effective, proportionate and dissuasive. Germany's implementation, for example, provides fines of up to €100,000 for serious administrative offences (€10,000 for lesser ones) and up to one year of imprisonment for persistent intentional violations that endanger life or health. Scales differ by country, so check the member state you actually ship to.

Sources: Amazon — GPSR seller requirements · Etsy Seller Handbook — selling to Europe under the GPSR · eBay Seller Center — GPSR · Baker McKenzie — Germany aligns product safety law with the GPSR · Regulation (EU) 2023/988, Arts. 22, 44 (EUR-Lex)

Common mistakes that get listings removed

Recurring patterns from marketplace compliance sweeps and authority checks — each maps to a specific Article 19 field the platforms scan for.

1. Your shop name in the manufacturer field. Article 19(1)(a) means the legal maker of the product. Resellers who enter their own trading name — or “OEM” / “no brand” — fail the field. The exception: white-label sellers marketing goods under their own trademark legally become the manufacturer, and then their details do belong there.
2. No EU responsible person on non-EU goods. The single most common suppression trigger for sellers outside the EU. Without an Article 16 operator, the product may not legally be placed on the EU market at all — and Amazon, Etsy and eBay all scan this field explicitly.
3. “Contact via marketplace messages” as the only contact. A chat link is neither a postal address nor an electronic address. Both must appear for the manufacturer, and for the responsible person where one is required.
4. English-only warnings shipped to non-English countries. Article 19(1)(d) requires the destination market's language. Candles, cosmetics or electronics with English-only safety text on offers served to France, Germany or Spain read as non-compliant on their face.
5. Compliance data buried inside a photo. Marketplace scanners read the structured compliance fields, not your product photography. Warnings that exist only as pixels in an image leave the fields empty, and the listing scans as missing them.
6. Assuming an exemption that does not exist. Handmade, small-batch, dropshipped and second-hand goods are all in scope. The genuine exclusions are narrow: antiques over 100 years old, products supplied for repair or reconditioning when clearly marked as such, and categories governed by their own regimes (food, medicines, live plants and animals).
7. A letterbox responsible person. An RP who holds none of your documentation fails their Article 16 duties the day an authority asks for the technical file — and the listing goes down with the inspection. Verify that your service actually stores your documentation, not just your money.

Frequently asked questions