GPSR Article 19, word for word

The text of Article 19

Article 19 sits in Chapter III, Section 2 of Regulation (EU) 2023/988, under the heading "Obligations of economic operators in the case of distance sales." It is a different provision from Article 4, which only defines when an online offer counts as "made available on the market" in the EU in the first place. Article 19 is the one that lists what has to appear on the offer itself.

Where economic operators make products available on the market online or through other means of distance sales, the offer of those products shall clearly and visibly indicate at least the following information:

The four disclosures, one at a time

(a) Manufacturer identity

name, registered trade name or registered trade mark of the manufacturer, as well as the postal and electronic address at which they can be contacted

This requires both a postal address and an electronic address for the manufacturer. An email-only contact, or a PO box that is not a real postal address, does not satisfy the wording as written.

(b) The EU Responsible Person, when the manufacturer is outside the EU

where the manufacturer is not established in the Union, the name, postal and electronic address of the responsible person within the meaning of Article 16(1) of this Regulation or Article 4(1) of Regulation (EU) 2019/1020

This clause only triggers where the manufacturer has no EU establishment, which is the normal case for a private-label seller sourcing from a factory outside the EU. See who needs a GPSR Responsible Person for who can fill that role.

(c) Product identification, including a picture

information allowing the identification of the product, including a picture of it, its type and any other product identifier

A picture is named explicitly, not implied. A text-only listing does not meet point (c), even if it names a SKU or model number. "Any other product identifier" uses the same open-ended language as the physical traceability mark in Article 9(5), covered in GPSR traceability numbers.

(d) Warnings and safety information

any warning or safety information to be affixed to the product or to the packaging or included in an accompanying document in accordance with this Regulation or the applicable Union harmonisation legislation in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market

The language standard, "easily understood by consumers, as determined by the Member State," is delegated to national governments rather than spelled out country by country in the regulation text. See GPSR warning language requirements for what is and is not sourced on that point.

"At least" is a floor, not a ceiling

Who this applies to

Article 19 addresses "economic operators" generally, a term Article 3(13) defines to cover the manufacturer, an authorised representative, the importer, the distributor, a fulfilment service provider, "or any other natural or legal person who is subject to obligations... in accordance with this Regulation." A seller who lists a product under their own account is inside that definition whether or not they physically manufactured it. Private-label sellers are treated as manufacturers outright under Article 13.

Article 22(9): the marketplace's mirrored duty

Article 19 obligates the seller to provide the four items. A separate provision obligates the marketplace itself to build somewhere for that information to go.

providers of online marketplaces shall design and organise their online interface in a way that enables traders offering the product to provide at least the following information for each product offered and that ensures that the information is displayed or otherwise made easily accessible by consumers on the product listing

Article 22(9) repeats the identical four-item list, word for word, as a duty on the platform to collect. That is why Amazon, eBay and Etsy each built a mandatory GPSR field into their listing flow: Article 22(9) requires the field to exist, Article 19 requires the seller to fill it in truthfully. See GPSR on Amazon for what that looks like in a real seller dashboard.

"Clearly and visibly" does not literally say "on the listing page"

How Article 19 relates to Article 9

Article 19 governs what a buyer sees online before purchase. Article 9 governs what has to be physically true of the manufacturer's product and packaging, including its technical documentation, its traceability mark and the language of any printed instructions. A compliant listing and a compliant physical product are two separate checklists that draw on some of the same underlying facts. See GPSR traceability numbers for the physical side.