Short answerSince 13 December 2024, the General Product Safety Regulation (EU) 2023/988 requires online offers to show the manufacturer, any EU responsible person, product identifiers with a picture, and warnings in the local language. PIM teams should model operators and warnings as governed, reusable entities linked to each product, with batch traceability held in ERP.
Key takeaways
- GPSR has applied since 13 December 2024 and Article 19 makes operator details, identification data and safety warnings mandatory in every distance sales offer.
- Modelling economic operators and warnings as linked reference entities lets one address or translation change update thousands of SKUs across all channels.
- A GPSR data programme typically runs in three waves over an estimated 3 to 9 months: operator data, then warnings and languages, then channel syndication.
GPSR makes safety information mandatory product data
The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024 to non-food consumer products that sector law does not fully cover. It replaced the General Product Safety Directive and moved several obligations from the label into the online offer itself. Product teams now carry legal duties for data that used to live in packaging artwork and printed leaflets. The practical consequence is simple: if an attribute is missing in the feed, the offer is non-compliant on every channel that receives it.
Four obligations drive the data model
Each GPSR obligation translates into a defined set of attributes, owners and validation rules.
| Obligation | Data required | Typical owner |
|---|---|---|
| Responsible economic operator | Name, postal and electronic address of the manufacturer and, for non-EU manufacturers, the EU-based responsible person | Legal or compliance |
| Product identification | Type, batch or serial number, picture, GTIN or other identifier | Product data team |
| Warnings and safety information | Text and pictograms in a language consumers in each member state easily understand | Compliance with localisation |
| Traceability | Supplier and customer records, batch-to-shipment links | Supply chain and ERP |
Article 19 requires distance sales offers to show manufacturer details, the responsible person where relevant, identification data including a picture, and any warnings or safety information. Online marketplaces must design their interfaces so traders can supply this information, register with the Safety Gate portal and act on authority orders. Large marketplaces now block or flag listings with empty GPSR fields, which turns a legal gap into lost revenue.
Model operators and warnings as reusable entities
Store economic operators and safety statements as linked reference entities instead of free text on each SKU. One manufacturer record typically serves thousands of products, and an address change should update every channel in one edit. The same logic applies to warnings.
- Operator entity: legal name, trade name or trademark, postal address, email or web contact, role (manufacturer, importer, responsible person, distributor), country of establishment.
- Warning entity: controlled code, approved source text, pictogram asset from the DAM, translations per locale with approval status, applicable product categories.
- Product link: references to one or more operators by role, list of warning codes, safety leaflet per language, batch or serial scheme.
- Validation rule: a product cannot reach 'ready for channel' status for a country until warnings exist in that country's required languages.
This structure governs each translation once and reuses it, which typically cuts localisation volume sharply compared with translating per SKU. Pictograms and instruction PDFs belong in the DAM with rights and version metadata, linked to the product record as described in DAM and PIM integration.
Traceability and recalls depend on batch-level links
GPSR traceability relies on ERP and warehouse data, with PIM supplying the identity layer. Economic operators must be able to identify who supplied them and to whom they supplied a product, and manufacturers keep technical documentation for 10 years. Batch or serial numbers have to appear on the product or, where size prevents that, on the packaging or accompanying documents.
Recalls test the whole chain. The regulation sets requirements for recall notices, including a standard template, clear wording and an effective remedy such as repair, replacement or refund. A recall that starts from a GTIN and a batch range needs to resolve, within hours, which channels sold the item, which listings must come down and which customers to contact. Organisations that hold batch data only in spreadsheets typically struggle to meet that pace, and accidents caused by a product must also be notified to authorities through the Safety Business Gateway.
Sequence the work by risk and channel pressure
A pragmatic GPSR programme runs in three waves over an estimated 3 to 9 months, depending on catalogue size and source data quality.
- Operator data first: collect and verify manufacturer and responsible person details for every brand, including private label and dropship suppliers.
- Warnings and languages second: build the warning library, map categories to warning codes and close translation gaps for priority markets.
- Syndication third: map GPSR attributes to each marketplace and retailer specification, following the patterns in product data syndication and GDSN.
Assign a single accountable owner per attribute group and report completeness per country. The approach in product data quality governance applies directly: completeness thresholds, approval workflows and audit trails provide the evidence a market surveillance authority may request. Teams comparing platform support for operator entities and locale-level validation can review options in the PIM and PXM suites overview.
Frequently asked questions
Does GPSR apply to products sold only online?
Yes. GPSR covers consumer products placed on the EU market through any channel, including distance sales. Article 19 adds specific display obligations for online offers, so the manufacturer details, identifiers, picture and warnings must appear in the listing before purchase, in addition to on the product or its packaging.
Who is the responsible person under GPSR?
For products covered by GPSR, an economic operator established in the EU must be responsible for safety tasks. This can be the manufacturer, an importer, an authorised representative or a fulfilment service provider. Their name, postal address and electronic address must be available on the product and in online offers.
Where should GPSR warnings be stored?
Store warnings as a governed library of coded statements with approved translations and linked pictograms. The PIM links warning codes to products and validates language coverage per market, while the DAM holds pictograms and instruction documents with version control. This avoids inconsistent free-text warnings across thousands of SKUs.