GPSR for online sellers: the mandatory information in every offer and how marketplaces collect it

What this is about

The GPSR has applied since 13 December 2024 (Art. 52) and replaced Directive 2001/95/EC (Art. 50(1)). It covers products intended for consumers or likely to be used by them (Art. 3(1)), whether new, used, repaired or reconditioned (Art. 2(3)). Exclusions include medicinal products, food and antiques (Art. 2(2)). Products with CE marking, such as toys, are also subject to Art. 19 and the marketplace obligations in Chapter IV (Art. 2(1), third subparagraph, point (b); Commission guidelines, section 2.2).

Note: This article is not legal advice. It summarises the wording of the regulations, the European Commission guidelines of 21 November 2025 and the marketplaces' help pages, as of 24 October 2026.

The four mandatory items under Article 19 GPSR

Anyone making products available online or through other means of distance sales must indicate at least the following in the offer, clearly and visibly:

E-mail or contact form? The English and French versions speak of an “electronic address”, the German version of an e-mail address. According to the guidelines, a dedicated contact section of your website through which consumers can reach you directly also counts; a website as such does not. The safe choice is a real e-mail address, not least because Amazon links contacts through it.

Language: In Germany, the warnings and safety information under Art. 19(d) must be written in German (section 6 no. 3 of the Product Safety Act, ProdSG, as reworded with effect from 19 February 2026). For other countries, their language applies. Where a product can be used safely without such information, it is not required (Art. 9(7), second sentence); the guidelines give knives as an example.

Manufacturer, responsible person, distributor

A manufacturer is anyone who manufactures a product, or has it manufactured, and markets it under their own name or trade mark (Art. 3(8)). Anyone placing a product on the market under their own trade mark is deemed to be the manufacturer (Art. 13(1)). For own brands, your company details therefore go in the manufacturer field, not the supplier's factory.

A product may only be placed on the market if an economic operator established in the EU is responsible for the tasks in Art. 4(3) of Regulation (EU) 2019/1020 (Art. 16(1) GPSR). Under Art. 4(2) of that regulation, this responsible person can only be:

• a manufacturer established in the EU,
• the importer, where the manufacturer is not established in the EU,
• an authorised representative with a written mandate from the manufacturer,
• a fulfilment service provider in the EU for the products it handles, where none of the other three is established in the EU.

This person provides documents to market surveillance authorities on request, reports risks and cooperates on corrective action (Art. 4(3)), and regularly checks that the product meets the labelling obligations in Art. 9(5) to (7) (Art. 16(2)).

Even as a pure distributor you are an economic operator (Art. 3(13)) and responsible yourself for the information in your offer. Before selling, you verify that the manufacturer and importer have met their labelling obligations (Art. 12(1)); if you have reason to doubt it, you may only sell once conformity has been restored (Art. 12(3)).

Obligations of online marketplaces under Article 22

• Input fields (para. 9): traders must be able to enter the four Art. 19 items for each product, and customers see them on the product listing or can easily access them. The content remains your responsibility.
• Deadlines: marketplaces act on orders from authorities within two working days at the latest (para. 4) and process product safety notices within three working days at the latest (para. 8).
• Suspension (para. 11): traders who frequently offer non-compliant products are suspended for a reasonable period after a warning.
• Recalls (para. 12): marketplaces notify affected buyers directly.

Paragraphs 9 and 11 specify obligations from the Digital Services Act and therefore, according to the Commission guidelines, only apply to medium and large marketplaces; small ones are covered only if designated as a very large online platform.

How Amazon, eBay, OTTO and Kaufland collect the information

Amazon

Seller Central help can only be read after logging in; this information comes from Amazon's developer documentation and an official announcement. You first create the manufacturer and the EU responsible person in Seller Central. In the listing, the manufacturer is linked by e-mail address at ASIN level and the responsible person at SKU level. Documents are uploaded with their language and a file URL, not as Google Drive or Dropbox links. The Account Health page shows affected offers. Caution: according to Amazon, full updates via legacy XML feeds overwrite GPSR information.

eBay

In the product safety section of the listing („Produkthinweise“ on ebay.de) you enter the manufacturer and, where it is not based in the EU or Northern Ireland, the EU responsible person. Additional safety information is limited to 120 characters without URLs; documents are uploaded as PDF, JPG or PNG with type and language. Model or batch number and EAN go into the item specifics.

OTTO Market

In the Products API v5, an address consists of the company name (at most 100 characters), the address on one line (at most 200 characters), a country code and an e-mail address or contact URL; the phone number is optional. Each address carries the role manufacturer or “distributor”, and at least one distributor address is mandatory.

Kaufland

Required fields are name, street, house number, postcode, town, country and an e-mail address or website URL; the phone number is optional. You manage the contacts in the Seller Portal on a dedicated GPSR page, one by one or via CSV; according to Kaufland, the old administration page was due to be removed on 15 May 2026. Safety notes go into the offer as an attribute in the local language, CE certificates as image or PDF.

Common gaps

1. Only the brand appears in the offer; postal or electronic address is missing (Art. 19(a)).
2. Manufacturer outside the EU, but no responsible person named (Art. 19(b)).
3. The responsible person given is a reseller without one of the roles in Art. 4(2) of Regulation (EU) 2019/1020.
4. For an own brand, the supplier's factory is named as manufacturer (Art. 13(1)).
5. Warnings only in English, although the product is sold in Germany (section 6 no. 3 ProdSG).
6. A full data feed overwrites the GPSR information entered earlier.

Checklist for every offer

Where AI helps and where it does not

Manufacturer, responsible person and warnings are facts from your documents; AI must neither invent nor fill them in. AI helps with the work around them. The ecomDNAI Marketplace Content Creator writes product copy to the rules and in the languages of the chosen marketplace, and a check shows before export what is still missing. You continue to maintain the GPSR fields in the seller portal.