--- title: "The marketplace says our product page lacks warnings" description: "An online offer must clearly and visibly show any warning or safety information that has to be on the product, on its packaging or in an accompanying document. The General Product Safety Regulation requires this for every distance sale, in a language consumers in the Member State easily understand. The warnings come from the manufacturer; the seller's job is to carry them over to the product page, complete and unchanged." type: "problem" url: "https://www.conphora.com/solutions/problem/product-images-warnings/" markdown: "https://www.conphora.com/solutions/problem/product-images-warnings.md" locale: "en" language: "en" updated: "2026-09-28" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/eli/reg/2023/988/oj" tags: ["GPSR", "marketplace-retailer"] license: "Free to quote with attribution and a link to the page" --- # The marketplace says our product page lacks warnings An online offer must clearly and visibly show any warning or safety information that has to be on the product, on its packaging or in an accompanying document. The General Product Safety Regulation requires this for every distance sale, in a language consumers in the Member State easily understand. The warnings come from the manufacturer; the seller's job is to carry them over to the product page, complete and unchanged. ## Why this happens Article 19 of the General Product Safety Regulation (EU) 2023/988 lists what an online offer must show. Point (d) covers any warning or safety information to be affixed to the product or to the packaging or included in an accompanying document, in accordance with the regulation or the applicable Union harmonisation legislation, in a language which can be easily understood by consumers. [1] The warnings themselves are the manufacturer's work. Manufacturers ensure that the product is accompanied by clear instructions and safety information in a language determined by the Member State in which the product is made available (Article 9(7)). Before selling, a distributor verifies that this was done (Article 12(1)). [1] Marketplaces collect the same information because they have to make it possible for traders to provide it and ensure that it is displayed (Article 22(9)). Market surveillance authorities can in turn require corrective action where information is missing (Regulation (EU) 2019/1020, Article 16, applied to products under the GPSR by its Article 23(1)). [2] ## How to solve it 1. **Collect the warnings from the product itself** Take the product, its packaging and its instructions and list every warning, age restriction and safety instruction on them. That list is what the offer has to show. 2. **Find out which rules put them there** Warnings come from the act the product falls under. Knowing the act tells you whether the list is complete. 3. **Put the full wording in the offer, in the right language** Show the warnings clearly and visibly on the product page, in a language that consumers in the country of sale easily understand, as that Member State determines. A small photo of packaging in another language does not do that. 4. **Add the other mandatory offer information at the same time** Manufacturer, responsible person and product identification are checked together with the warnings. ## What you need to show - **Warnings and safety information as they appear on the product** — The manufacturer (GPSR Article 19(d)) - **Instructions and safety information in the language of the Member State** — The manufacturer (GPSR Article 9(7)) - **Product identification, including a picture** — You, in the listing (GPSR Article 19(c)) ## If you do nothing - **The offer does not meet Article 19** — The offer must clearly and visibly indicate any warning or safety information to be affixed to the product or its packaging or included in an accompanying document (GPSR Article 19(d)). - **The distributor's own duty** — A distributor verifies, before making a product available, that the manufacturer and the importer complied with the marking and information requirements (GPSR Article 12(1)). - **Penalties under national law** — Each Member State sets its own penalties for infringements of the regulation (GPSR Article 44). ## Questions ### Is a picture of the warning label enough? The regulation asks for the information to be indicated clearly and visibly. A legible picture in the right language may do that; a small or foreign-language picture does not. ### Who decides which language? The Member State where the product is made available determines the language consumers must be able to understand easily. ### Our supplier gave us no warnings. Can we write them ourselves? The warnings follow from the manufacturer's risk analysis and the act the product falls under. Ask the manufacturer first; a seller that invents them takes on a risk it cannot assess. ## Regulations involved GPSR ## Sources 1. [Regulation (EU) 2023/988 on general product safety](https://eur-lex.europa.eu/eli/reg/2023/988/oj) — EUR-Lex, 2026-09-21 2. [Regulation (EU) 2019/1020 on market surveillance and compliance of products](https://eur-lex.europa.eu/eli/reg/2019/1020/oj) — EUR-Lex, 2026-09-21