Our label has no EU address on it

The General Product Safety Regulation (EU) 2023/988 makes identification part of the product. Manufacturers indicate their name, registered trade name or trade mark, their postal and electronic address and, where different, the address of a single contact point. That information is placed on the product or, where that is not possible, on its packaging or in a document accompanying the product (Article 9(6)). Importers indicate their own details in the same way and make sure that any additional label does not obscure information required by Union law on the manufacturer's label (Article 11(3)).^[1]

The duty runs down the chain. Before placing a product on the market, an importer makes sure the manufacturer has complied with Article 9(5) and (6) (Article 11(1)). Before making a product available, a distributor verifies that the manufacturer and the importer have complied with those requirements (Article 12(1)), and does not sell while it has reason to believe they have not (Article 12(3)). The regulation has applied since 13 December 2024 (Article 52). Older stock placed on the market before 13 December 2024 in conformity with Directive 2001/95/EC may still be made available (Article 51); the Commission's guidelines add that the new traceability information requirements do not apply to them (Commission Notice C/2025/6233, section 2.1).^[1]

When the manufacturer is outside the EU, a product covered by the GPSR may only be placed on the market if an economic operator established in the Union is responsible for it (Article 16(1)). That operator's name, registered trade name or trade mark and contact details, including the postal and electronic address, go on the product or on its packaging, the parcel or an accompanying document (Article 16(3)). Regulation (EU) 2019/1020 sets a similar rule for products under the harmonisation acts listed in its Article 4(5), where the contact details include the postal address (Article 4(1) and (4)).^[1][2]

For products covered by Union harmonisation legislation, Chapter III, Section 1 of the GPSR, which holds the manufacturer and importer duties, does not apply (Article 2(1)(b)). The sector act then sets the rule. Under the Low Voltage Directive, manufacturers and importers give their name and a postal address on the equipment or, where that is not possible, on its packaging or in an accompanying document, in a language easily understood by end users and market surveillance authorities (Directive 2014/35/EU, Articles 6(6) and 8(3)).^[3]

Online offers repeat the details. Where products are sold online or at a distance, the offer clearly and visibly shows the manufacturer's name and postal and electronic address, and, where the manufacturer is not established in the Union, the name and addresses of the responsible person (GPSR Article 19(a) and (b)). Article 19 sits outside Section 1, so it also applies to products under harmonisation legislation.^[1]