GPSR Article 19: what your online product listing must show

What Article 19 covers

Article 19 applies to distance sales, which for most Shopify merchants means offering a product online. Where a product is made available on the market through an online offer, the offer must clearly show four elements. The word “clearly” matters: the point is that a shopper can see this information on the listing before they decide to buy, not that it is buried in a document they only receive after purchase.

The four elements are labelled (a) to (d) in the regulation. The table below summarises them, and the sections that follow take each one in detail with a note on how to put it on a Shopify product page.

(a) The manufacturer

The listing must show the manufacturer’s name, registered trade name or trademark, together with a postal address and an electronic means of contact. The manufacturer is the party that makes the product, or that has it made and markets it under their own name or trademark. The postal address should be one at which they can be reached, and the electronic contact is typically an email address or a contact form.

On a Shopify product page, this is a short block of text: the manufacturer’s name and trademark, their postal address, and their contact email. Because the same manufacturer often supplies many of your products, it is worth recording the details once per manufacturer and reusing them, rather than retyping them for every product.

(b) The responsible person, for non-EU manufacturers

Where the manufacturer is not established in the EU, the listing must also show the name, address and contact details of the responsible person, as defined in Article 16. The responsible person is an economic operator established in the EU who is responsible for certain tasks in relation to the product. Whether such a person must exist is a duty on the manufacturer or importer placing the product on the market, not on you as the retailer. Your job under element (b) is to show that person’s details on the listing.

The practical trigger is whether the manufacturer is inside or outside the EU. On a Shopify product page, a simple “made outside the EU” flag tells you whether element (b) is needed, and if it is, you show the responsible person’s name, address and contact. Our EU responsible person page explains who can act as one and what the role involves.

(c) Product identification

The listing must include information that identifies the product, including a picture of it, its type, and any identifier such as a model number or batch code. The purpose is that a shopper, and an authority, can tell precisely which product the offer is for. A picture alone is not the whole of element (c): the type and the identifier are part of it too.

On a Shopify product page much of this is already present. You have a product image and a title, and often a SKU or model. Element (c) is about making sure the type and any identifier are actually shown, not just held internally. Where a product has a model number or batch identifier, it should appear on the listing alongside the picture.

(d) Warnings and safety information

The listing must show any warning or safety information that has to be affixed on the product or to accompany it. This is the safety content a shopper needs to see before buying, for example age warnings, handling instructions, or hazard statements, depending on the product. Article 19(d) ties the required warnings to the applicable law: it refers to the information required “by this Regulation or by the applicable Union harmonisation legislation”.

That is the dual legal basis. For a general, non-harmonised product the warnings come from the GPSR itself. For a product covered by specific EU harmonisation law, for example a toy, an electronic item, a cosmetic, PPE, machinery, or a medical device (typically CE-marked), the equivalent online-information duty comes from Regulation (EU) 2019/1020 (market surveillance), Article 4, together with the sector legislation. Either way, the warnings are shown on the listing. The difference is the legal source, and deciding which regime applies to a given product is a judgement about the product, not something an app can decide for you.

The language requirement

Element (d) adds a language condition: the warnings and safety information must be in a language easily understood by consumers. In practice that means providing the information in the language of the market you are selling into, so a shopper can actually read and understand it. If you sell the same product into several EU countries, the safety information may need to appear in more than one language so that it is understood in each market.

Putting the four elements on a Shopify product page

1. Record the manufacturer once: name, registered trade name or trademark, postal address, and electronic contact. Reuse it across the products that share that manufacturer.
2. Set a “made outside the EU” flag per product. Where it is set, record the EU responsible person’s name, address and contact so element (b) is covered.
3. Make sure the product type and any model or batch identifier are shown on the listing alongside the product picture, for element (c).
4. Add the warnings and safety information for element (d), in a language easily understood by consumers in each market you sell into.
5. Display all four elements clearly on the live product page, and check that they are actually visible to shoppers rather than held only in your admin.

How Safira helps

Safira is a configuration and documentation tool for Shopify built around Article 19. It adds fields to the Shopify product editor for the manufacturer, the EU responsible person, the safety information, and a “made outside the EU” flag, so the four elements have a home against each product. Its theme block shows those details on the product page, and it reads your live theme to confirm the block is actually showing. A readiness scan reads your catalogue and counts which products are still missing information, so you can close the gaps. It requests two Shopify permissions, write_products and read_themes, and never touches orders or customer data. Safira shows and scores the display; it does not certify that a listing is legally complete and does not decide which legal regime a product falls under.

Frequently asked questions

What does GPSR Article 19 require online sellers to show?

Where a product is offered online, Article 19 requires the listing to clearly show four things: the manufacturer’s name, registered trade name or trademark and postal plus electronic contact; where the manufacturer is not established in the EU, the responsible person’s details as in Article 16; product identification including a picture, the type and any identifier; and any warning or safety information to be affixed on the product or to accompany it, in a language easily understood by consumers.

What language do the warnings have to be in?

Article 19 requires the warnings and safety information to be in a language that is easily understood by consumers. In practice that means the information should be provided in the language of the market you are selling into, so a shopper can actually understand it before buying.

Do I always show a responsible person on the listing?

Only where the manufacturer is not established in the EU. In that case element (b) applies and the listing must show the responsible person’s name, address and contact details. Where the manufacturer is established in the EU, element (a) covers the manufacturer and (b) does not add a separate responsible-person line.

Does the picture in element (c) mean my normal product photo?

Element (c) asks for information that identifies the product, including a picture of it, its type and any identifier such as a model or batch number. A clear product image plus the type and identifier lets a shopper and an authority tell exactly which product the listing is for. A single decorative image on its own may not be enough if the type and identifier are missing.

Can Safira put these four elements on my product page?

Safira adds fields for the manufacturer, the EU responsible person, and the safety information to the Shopify product editor, and a theme block that shows those details on the product page. It reads your live theme to confirm the block is showing, and scans your catalogue to count which products still have gaps. It shows and scores the display; it does not certify that a listing is legally complete.