The EU General Product Safety Regulation (GPSR), (EU) 2023/988, has applied since 13 December 2024 to all products within its scope, wherever they are made. A product must carry a type, batch or serial number or another element that identifies it, show the manufacturer's name with postal and electronic addresses, and, where the manufacturer is outside the EU, name a responsible person established in the EU. The regulation does not choose the identifier for you. That depends on the smallest unit you need to separate when something goes wrong.
Does the GPSR apply to your product?
The regulation excludes groups such as medicines, food, feed and plant protection products (Article 2(2)). Products with their own EU legislation are split. For goods under harmonisation legislation, such as toys, cosmetics or electrical products, the section containing Articles 9, 11 and 16 does not apply, and identification rules come from the product's own legislation. Article 19 on distance sales and Article 20 on accident reporting still apply to them.
The sales channel matters too. Under Article 4, a product offered online is deemed to be made available on the market if the offer targets consumers in the Union. Having no office in the EU does not by itself put you outside the scope.
What information has to be on the product?
| Information | Where it goes | Basis |
|---|---|---|
| Type, batch or serial number, or another identifying element | Product; if size or nature prevents this, packaging or accompanying document | Article 9(5) |
| Manufacturer's name, registered trade name or trade mark, postal and electronic address | Product; if not possible, packaging or accompanying document | Article 9(6) |
| Name and contact details of the EU responsible person | Product, packaging, parcel or accompanying document | Article 16(3) |
| Importer's name and addresses | Product; if not possible, packaging or accompanying document | Article 11(3) |
| Instructions and safety information | In a language easily understood by consumers, as set by the Member State of sale | Article 9(7) |
The Commission's November 2025 guidelines clarify two practical points. As a rule, only the size of the product can justify moving information from the product to its packaging; aesthetic reasons do not, and you should be able to defend the choice. An electronic address must be an email or website section through which consumers can reach you directly; a website address alone is not enough.
An importer's additional label must not cover the manufacturer's mandatory information. Reserve that space when designing the label.
Who can be the responsible person?
Under Article 16, a product cannot be placed on the market unless an economic operator established in the Union is responsible for it. According to the Commission's guidelines, for a manufacturer outside the EU that can be the importer, an authorised representative with a written mandate, or, where no other operator is established in the EU, a fulfilment service provider handling the product.
Depending on the risk, the responsible person regularly checks that the product matches the technical documentation and the identification rules, and must provide evidence of those checks to authorities on request. The contract should state how it gets access to the technical file and batch information.
Type, batch or serial number?
Article 9(5) accepts any of them. The difference appears at the moment of a recall or a complaint. Article 36 requires a recall notice to include identification numbers such as batch or serial number, and Article 9(8) calls for the quantity on the market by Member State, where available. A type number on its own spreads a problem across the whole model.
| Identifier | Accepted under the GPSR? | Contribution to traceability | Does it prove authenticity? |
|---|---|---|---|
| Type or model number | Yes | Shows the model, not the batch | No, it can be copied straight off the product |
| Batch number | Yes | Targeted recalls, complaints linked to production records | No, the same number repeats across the batch |
| Serial number | Yes | Unit history and shipment record | Not alone; with a scan record, a repeating number becomes visible |
| Barcode | Yes, if it identifies the product | Depends on its data; a GTIN shows only the product type | No |
We cover this choice in the batch and serial number article, and why a number alone is not verification in the article on tracking and verification.
Can a QR code replace the mandatory information?
No. Article 21 allows the information to be offered digitally as well, but only "additionally". The identifier and the manufacturer and responsible person details must still physically appear where the regulation requires. A QR code can add access to a manual or fuller safety information.
Article 18 separately empowers the Commission to set up a traceability system, which may include a data carrier, for certain product groups likely to present a serious risk. That power is not a general QR requirement for every product today.
What must an online listing show?
Under Article 19, the offer must clearly and visibly show at least the manufacturer's name and addresses, the responsible person's name and addresses where the manufacturer is outside the EU, information identifying the product including a picture, its type and any other identifier, and required warnings and safety information. Article 22(9) requires online marketplaces to build interfaces that let traders enter this information and show it to consumers on the listing. Product, packaging and listing should match.
Which records must be kept?
- Internal risk analysis and technical documentation, for 10 years after the product is placed on the market (Articles 9(2) and 9(3)).
- A public channel for consumers to report complaints and accidents (Article 9(11)).
- An internal register of complaints about allegedly dangerous products, recalls and corrective measures. Personal data in it is kept for no more than five years (Articles 9(12) and 9(13)).
For the equivalent rules in Türkiye, see our article on Law No. 7223.
Checklist
- Establish whether the product falls under the GPSR or sector-specific legislation.
- Choose an EU responsible person and put the tasks in a contract.
- Choose the identifier level according to the unit you would want to separate in a recall.
- Put the identifier on the product; if you move it to the packaging, record the reason.
- Link the batch number to production and shipment records.
- Confirm that product, packaging and listing show the same information.
What does Spectrace do here?
Tagvex fits a batch or unit number into the existing label layout and records every change of hands, which ties the number to production and shipment records. The Grafex invisible signature is for verification and does not replace the visible, legible identifier the GPSR asks for. These records do not replace your own compliance assessment under the regulation.
