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Marketplace and retailer demands Online seller 5 min read

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.

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Reviewed 28 September 2026 by the Conphora compliance team · Not legal advice

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.

    Free compliance checkerCompliance engine Free Open
  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.

    Regulation guidesKnow-how Free Open

Work through the steps in the platform with your own product.

What you need to show

DocumentWhere it comes fromLegal ground
Warnings and safety information as they appear on the productThe manufacturerGPSR Article 19(d)
Instructions and safety information in the language of the Member StateThe manufacturerGPSR Article 9(7)
Product identification, including a pictureYou, in the listingGPSR 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)).[1]

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)).[1]

Penalties under national law

Each Member State sets its own penalties for infringements of the regulation (GPSR Article 44).[1]

Questions about this problem

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.

Follow changes to the rules behind this problem

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Sources

  1. Regulation (EU) 2023/988 on general product safety EUR-Lex · accessed 21 September 2026
  2. Regulation (EU) 2019/1020 on market surveillance and compliance of products EUR-Lex · accessed 21 September 2026

About this page

Reviewer
Conphora compliance team
Reviewed
28 September 2026
Cite this page
Conphora (2026). The marketplace says our product page lacks warnings. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/product-images-warnings/
Reviewed
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