A trading name of A Star Supply · ContactA trading name of A Star Supply · ContactWith print-on-demand, someone else prints and ships the product, but your shop name is on the sale. The General Product Safety Regulation decides who the manufacturer is by whose name the product is sold under, not who owns the printer. Here is what the text says, and what Printful, Printify and Gelato say on their own help pages. This is a plain-English summary, not legal advice.
Article 3(8) defines a manufacturer as any natural or legal person who manufactures a product or has a product designed or manufactured, and markets that product under that person's name or trademark. Article 13(1) adds that anyone who places a product on the market under their own name or trademark is deemed a manufacturer and has the Article 9 manufacturer duties.
The European Commission's 2025 guidelines give an example that fits print-on-demand closely: company A buys mugs made by company B, brands them with its logo and sells them to consumers. Company A becomes the manufacturer of those mugs.
Printful and Gelato both tell sellers, whether inside or outside the EU, to name themselves as the manufacturer. Printify says that where a marketplace has separate fields, you enter your contact information as the manufacturer.
Having a partner print the goods does not move the manufacturer role to them if the product is sold under your name or trademark.
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. Under Article 4(2) of Regulation (EU) 2019/1020 that operator is an EU manufacturer, an importer, an authorised representative with a written mandate from the manufacturer, or, where none of those is established in the EU, an EU fulfilment service provider for the products it handles. If you are in the EU yourself, you can be it as the manufacturer.
Its name and contact details, including postal and electronic address, go on the product, its packaging, the parcel or an accompanying document (Article 16(3)), and in the listing where the manufacturer is outside the EU (Article 19(b)).
None of these pages says which of the four Article 4(2) roles the named company holds for your products. Instilus is not a Responsible Person and does not provide that role.
The identifier and manufacturer details go on the product, or on the packaging or an accompanying document only where the product does not allow it (Article 9(5) and (6)). The three provider help pages we read deal with listings; none of them explains how the manufacturer's details are put on the product, its packaging or an accompanying document.
Before placing a product on the market, the manufacturer must carry out an internal risk analysis and draw up technical documentation: at least a general description of the product and its essential characteristics relevant for assessing its safety, plus the risk analysis, test results and standards applied where appropriate to the possible risks (Article 9(2)). It is kept up to date and available to authorities for 10 years (Article 9(3)).
Recital 33 says the amount of information should be proportionate to the complexity of the product and the possible risks. Your Responsible Person checks, where appropriate, that the product matches the documentation (Article 16(2)).
The providers supply product information you can use as an input: Printful points to its product catalogue and GPSR product lists, Printify says it will supply the required product information, and Gelato says it has a list of product safety compliance information, age guidelines and care instructions for every product category. None of the three pages mentions technical documentation or the internal risk analysis.
Whatever the provider says about warnings, Article 19 requires the listing to show the manufacturer, the Responsible Person where applicable, product identification with a picture, and any warnings or safety information that apply.
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.
Printify's page says the GPSR requires the general EU two-year warranty in the product description. Gelato's page says the GPSR does not include an obligation to mention the legal guarantee, while the seller has a pre-contractual duty to state it. Printful points to the two-year legal guarantee under Directive (EU) 2019/771.
For the record: the list of listing information in Article 19 of the GPSR does not include warranty information. All three providers agree the two-year legal guarantee to EU consumers is the seller's responsibility.
Under Article 3(8), the manufacturer is whoever has the product made and markets it under their own name or trademark. If your products are sold under your shop name or brand, that is you. Printful and Gelato both tell sellers to name themselves as the manufacturer.
Printful and Gelato each give an EU company for sellers outside the EU to use; Printify tells sellers outside the EU to appoint someone established in the EU. Article 16 requires an EU manufacturer, importer, authorised representative with a written mandate, or EU fulfilment service provider. Check with the provider which of those roles it holds.
The Article 9(2) duty to carry out an internal risk analysis and draw up technical documentation is the manufacturer's. The provider's product information can go into it, but none of the three providers' GPSR pages says it prepares the documentation for you.
Article 20 puts the notification duty on the manufacturer, through the Safety Business Gateway. Where the manufacturer is outside the EU, the Responsible Person who knows about the accident must ensure it is notified.
Etsy says that depending on the role a production partner plays, they may have obligations under the GPSR. It does not say whether the seller or the partner is the manufacturer.
Instilus organises the documents you already have into a GPSR evidence pack. Take the free eligibility check.
One email with the checklist, the label generator, the templates and the example pack. No account, and nothing else is sent unless you ask.