A trading name of A Star Supply · ContactA trading name of A Star Supply · ContactThe General Product Safety Regulation does not have one "label" article. The duties are spread across the articles for manufacturers, importers and the EU responsible person. Here they are in one place, with the article each comes from.
Article 9(5) says manufacturers must ensure their products bear a type, batch or serial number or other element enabling the identification of the product, which is easily visible and legible for consumers.
Where the size or nature of the product does not allow it, the information goes on the packaging or in a document accompanying the product. The European Commission's 2025 guidelines give a barcode as an example of an "other element".
Article 9(6) says this information goes on the product or, where that is not possible, on its packaging or in a document accompanying the product.
The Commission's guidelines explain that an electronic address can be an email address or a dedicated section of a website that lets consumers contact you directly. A website alone is not enough if it does not allow direct communication.
Where there is an importer, Article 11(3) requires it to indicate its own name, registered trade name or registered trade mark, and postal and electronic address (plus a single contact point where different), on the product or, where that is not possible, on its packaging or in an accompanying document.
The same paragraph says any additional label the importer adds must not obscure information required by EU law on the manufacturer's label.
Article 16(1) says a product cannot be placed on the EU market unless an economic operator established in the EU is responsible for it. Article 16(3) says that operator's name, registered trade name or registered trade mark, and contact details including postal and electronic address, must be indicated on the product or on its packaging, the parcel or an accompanying document.
Note the wider list: the responsible person's details may go on the parcel, which is not an option for the manufacturer's own details under Article 9(6).
Instilus is not a responsible person and does not provide that role. The appointment is one you make yourself.
Article 9(7) requires the product to be accompanied by clear instructions and safety information in a language consumers can easily understand, as determined by the EU country where it is made available. Importers have the same duty under Article 11(4).
This does not apply where the product can be used safely and as intended without such instructions and safety information. The Commission's guidelines give products with well-known risks, such as knives, as an example.
Article 21 allows the information to be made available additionally in a digital format, such as a code on the product. It is extra, not a replacement.
The wording differs slightly by item. The identifier may move off the product where "the size or nature of the product does not allow it" (Article 9(5)). Manufacturer and importer details may move where putting them on the product "is not possible" (Articles 9(6) and 11(3)).
The Commission's guidelines say the decision is yours within that framework, and that you should be able to justify it in a dispute. They add that in principle only the size of the product, and not for example aesthetic reasons, could justify moving required information from the product to its packaging or accompanying documents.
"It would spoil the look" is exactly the reason the Commission says does not justify leaving the details off the product.
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A type, batch or serial number or other identifier (Article 9(5)); the manufacturer's name or registered trade name or trade mark with postal and electronic address (Article 9(6)); the importer's equivalent details where there is one (Article 11(3)); and the EU responsible person's details (Article 16(3)). Instructions and safety information must accompany the product unless it can be used safely without them (Article 9(7)).
Only where the product itself does not allow it. The Commission's guidelines say that in principle only the product's size, not aesthetics, justifies moving required information to the packaging or an accompanying document.
Yes. Article 16(3) lists the product, its packaging, the parcel or an accompanying document.
Not on its own. The Commission's guidelines say an email address or a dedicated website section that lets consumers contact you directly works; a website that does not allow direct communication does not.
No. Article 21 allows digital formats in addition to the information required by Articles 9, 11 and 16, not instead of it.
Want this done for you? The $24 Listing Information Pack formats your details for Amazon, Etsy, eBay and Shopify. Or use the free label generator on this site to produce the label text yourself.
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One email with the checklist, the label generator, the templates and the example pack. No account, and nothing else is sent unless you ask.