EU user manual requirements under GPSR

The instructions are yours to write, but the language is not yours to pick (Art. 9(7)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 7Click opens the article on EUR-Lex.).

What the law asks for

One sentence carries the whole duty. Manufacturers ensure their product comes with clear instructions and safety information “in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market” (Art. 9(7)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 7Click opens the article on EUR-Lex.).

That is four demands in one line:

• Accompanied by. The information travels with the product.
• Clear.
• Instructions and safety information. Two different things. A manual that explains assembly but never warns is short of the second.
• The language the EU country sets, not the language you prefer.

GPSR asks for information in three places. The label on the product and the fields on the offer page are the other two, and all three sit together on GPSR labelling requirements. Whether the Regulation reaches your product at all is the GPSR guide. The same test in prose: does GPSR apply to me. What must be printed on the product itself, drawn element by element, is the GPSR label.

When you may leave them out

The exemption is real and it is in the same paragraph. The duty “shall not apply where the product can be used safely and as intended by the manufacturer without such instructions and safety information” (Art. 9(7)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 7Click opens the article on EUR-Lex.). Art. 11(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 11, paragraph 4Click opens the article on EUR-Lex. carries the same exception for an importerArt. 3(10)any natural or legal person established within the Union who places a product from a third country on the Union marketClick the term for the full definition.

Two things bound it. The test is about the product, not about your workload, and it has two halves: safely and as intended. A product that is obvious to use but carries a hazard a buyer would not expect fails the first half. An authority deciding whether the product is safe at all weighs four things together: the presentation of the product, its labelling, its warnings, and its instructions for safe use and disposal (Art. 6(1)(d)Regulation (EU) 2023/988, General Product Safety RegulationArticle 6, paragraph 1, point (d)Click opens the article on EUR-Lex.). So the manual carries every hazard the product does not make obvious by itself, and it is left out only where a buyer meeting the product cold comes to no harm.

A pencil, a cotton t-shirt, a ceramic mug: nothing to write. The genuine edge case is a simple-looking product with a hazard the buyer cannot see - a scented candle, a magnet set sold to adults. Those are used without a manual and still carry the warning.

What goes in the instruction set

GPSR says “clear instructions and safety information” and stops. The Commission’s 2022 Blue Guide lists the contents, and it is written for Union harmonisation legislationArt. 3(27)Union legislation listed in Annex I to Regulation (EU) 2019/1020 and any other Union legislation harmonising the conditions for the marketing of products to which that Regulation appliesClick the term for the full definition rather than for GPSR, so it is doctrine on what “clear” means and not a GPSR rule. Its words:

This should include all the necessary information for the safe use of the product, to enable the consumer to assemble, install, operate, store, maintain, and dispose of the product. Instructions for assembly or installation should include the inventory parts and special skills or tools. Instructions on operation should include information for restriction of use, need for personal protective equipment, maintenance and cleaning or repair.

And on who you are writing for:

Manufacturers have to look beyond what they consider the intended use of a product and place themselves in the position of the average user of a particular product and envisage in what way they would reasonably consider to use the product.

So the checklist is: the parts inventory and the tools or skills assembly needs; how to operate it, what it must not be used for, and any protective equipment; cleaning, maintenance and repair; storage; disposal. The reader is the average buyer, not the engineer who designed it.

Whether a manual is “clear” is the market surveillance authority’s call, case by case. No official test exists beyond the Blue Guide’s “clear, understandable and intelligible”.

• Under the sector laws, a standard symbol may replace words: “The use of symbols according to international standards may be an alternative to written statements” (Blue Guide, footnote 110). That is Commission doctrine, not GPSR law.
• Toys: “The warnings shall be preceded by the words ‘Warning’ or ‘Warnings’, as the case may be” (Directive 2009/48/EC, Art. 11(2)Directive 2009/48/EC, Toy Safety DirectiveArticle 11, paragraph 2Click opens the article on EUR-Lex.). Some warnings must be used as worded in Annex V, Part B (Art. 11(1)Directive 2009/48/EC, Toy Safety DirectiveThe whole regulationClick opens the law on the EU Publications Office.).
• Cosmetics: the label carries “particular precautions to be observed in use, and at least those listed in Annexes III to VI” (Regulation (EC) No 1223/2009, Art. 19(1)(d)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1, point (d)Click opens the article on EUR-Lex.). Those annexes give the wording of the warnings for listed substances.

Paper, PDF, or a QR code

Under GPSR, the instructions and the safety information both travel with the product, and a digital copy only adds to them. Under the sector laws, the safety information goes on paper and the rest of the instructions may be digital, unless that law says otherwise. The Blue Guide, footnote 114, doctrine for harmonisation law rather than GPSR law:

Unless otherwise specified in specific legislation, whilst the safety information needs to be provided on paper, it is not required that all the set of instructions is also provided on paper but they can also be on electronic or other data storage format or even a website. Where this is the case, the full set of instructions must remain accessible for a reasonable period after the product was placed on the market depending on the intended use of the product. However, a paper version should always be available free of charge for the consumers who request it.

GPSR’s own rule on the digital copy is stricter. Economic operatorsArt. 3(13)the manufacturer, the authorised representative, the importer, the distributor, the fulfilment service provider or any other natural or legal person who is subject to obligations in relation to the manufacture of products or making them available on the market ...Click the term for the full definition may additionally make the information available in digital format, clearly visible on the product or, where that is not possible, on its packaging or in an accompanying document, in a language easily understood by consumers as set by the EU country, and in formats accessible to persons with disabilities (Art. 21Regulation (EU) 2023/988, General Product Safety RegulationArticle 21Click opens the article on EUR-Lex.). “Additionally” is the operative word. The Commission’s GPSR FAQ puts it flatly: digital labelling alone does not suffice, and digital comes in addition to the physical information, not instead of it. The Dutch regulator says the same: a QR code supplements what is on the product, it does not replace it.

Which language

Each EU country where the product is sold decides (Art. 9(7)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 7Click opens the article on EUR-Lex., Art. 11(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 11, paragraph 4Click opens the article on EUR-Lex., Art. 19(d)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (d)Click opens the article on EUR-Lex., Art. 21Regulation (EU) 2023/988, General Product Safety RegulationArticle 21Click opens the article on EUR-Lex.). Six of them, as their texts stood when read on 5 October 2026, show different shapes:

Four of them, in their own words:

Germany. Produktsicherheitsgesetz § 6 requires the instructions and safety information, the warnings and the information to be drawn up “in deutscher Sprache”. Unofficial translation: in the German language. German is not a preference there; it is the statute’s word. The full paragraph, verbatim, is on the GPSR label page, where it also shows which requirements the language rule does not touch.

France. The DGCCRF restates the law of 4 August 1994: to use equipment properly and keep themselves and those around them safe, the consumer must have “notices d’emploi et d’instructions rédigées en français”. Unofficial translation: user instructions and directions written in French. The DGCCRF page also tells consumers they may report a product whose instructions are only in a foreign language with no legible, visible French translation.

The Netherlands. The NVWA tells manufacturers: “Lever producten met duidelijke instructies en veiligheidsinformatie in een voor Nederlandse consumenten begrijpelijke taal”. Unofficial translation: supply products with clear instructions and safety information in a language Dutch consumers can understand. A QR code pointing to a website with that information is allowed as a supplement to what is on the product.

Ireland. S.I. No. 726/2024, Regulation 5: where an economic operator, manufacturer, authorised representative, importer or a provider of an online marketplace makes information available “pursuant to Article 9, 10, 11, 19, 21, 22 or 36, that information shall be in English.”

The working rule across the six: use the national language of each market you sell into, and depart from it only where that country’s own determination allows it. Each of the other 21 EU countries sets its own determination. A regional language inside a country follows that country’s own rule; the Dutch NVWA text sets no Frisian rule.

• Electrical equipment (Low Voltage Directive, Directive 2014/35/EUDirective 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.): instructions and safety information in the language the EU country sets, the same as GPSR.
• Toys (Directive 2009/48/EC): the same, plus mandatory warnings, some of them worded by the law itself. Which warnings, and where they must show online, is on CE marking for toys.
• Radio equipment (Directive 2014/53/EU, see Radio Equipment Directive): the instructions describe accessories and software, each item comes with a copy of the EU declaration of conformity or a simplified one, and the packaging shows any national restrictions on use.
• Machinery, from 20 January 2027 (Regulation (EU) 2023/1230): the instructions follow that law’s own content list and may be digital, but the buyer gets paper free of charge within one month on request, and safety information for non-professional users is always on paper. What the Machinery Directive asks until then, and which units follow which law, is in Machinery Regulation and Machinery Directive.
• Medical devices (Regulation (EU) 2017/745): the label and instructions follow that law’s own content list, in the official language or languages the EU country sets.
• Cosmetics (Regulation (EC) No 1223/2009): the precautions for use go on the container and the packaging; the whole label is in EU Cosmetics Regulation.

The articles: Art. 6(5)Directive 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.-(7) of Directive 2014/35/EUDirective 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.; Art. 4(5)Directive 2009/48/EC, Toy Safety DirectiveThe whole regulationClick opens the law on the EU Publications Office.-(7), Art. 11Directive 2009/48/EC, Toy Safety DirectiveThe whole regulationClick opens the law on the EU Publications Office. and Annex V of Directive 2009/48/ECDirective 2009/48/EC, Toy Safety DirectiveThe whole regulationClick opens the law on the EU Publications Office.; Art. 10(6)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.-(10) of Directive 2014/53/EUDirective 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.; Art. 10(5)Regulation (EU) 2023/1230, Machinery Regulation (consolidated text of 27 July 2026)The whole regulationClick opens the law on the EU Publications Office.-(8) and Annex III of Regulation (EU) 2023/1230Regulation (EU) 2023/1230, Machinery Regulation (consolidated text of 27 July 2026)The whole regulationClick opens the law on the EU Publications Office.; Art. 10(11)Regulation (EU) 2017/745, Medical Devices Regulation (consolidated text of 19 July 2026)The whole regulationClick opens the law on the EU Publications Office. and Annex I Section 23 of Regulation (EU) 2017/745Regulation (EU) 2017/745, Medical Devices Regulation (consolidated text of 19 July 2026)The whole regulationClick opens the law on the EU Publications Office.; Art. 19(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationThe whole regulationClick opens the law on the EU Publications Office. of Regulation (EC) No 1223/2009Regulation (EC) No 1223/2009, Cosmetic Products RegulationThe whole regulationClick opens the law on the EU Publications Office.. The machinery rule in its own words (Art. 10(7)): “The instructions may be provided in a digital format. […] However, at the request of the user at the time of the purchase, the manufacturer shall provide the instructions for use in paper format free of charge within one month.”

What each of these laws adds to the label itself is on GPSR labelling requirements.

Who owes them, and who checks

The manufacturerArt. 3(8)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 trademarkClick the term for the full definition makes sure the product comes with them (Art. 9(7)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 7Click opens the article on EUR-Lex.). An importerArt. 3(10)any natural or legal person established within the Union who places a product from a third country on the Union marketClick the term for the full definition owes the same for the product it imported (Art. 11(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 11, paragraph 4Click opens the article on EUR-Lex.). A distributorArt. 3(11)any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a product available on the marketClick the term for the full definition, before making the product available, verifies that the manufacturer and, where applicable, the importer met Art. 9(5)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 5Click opens the article on EUR-Lex., (6) and (7) and Art. 11(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 11, paragraph 3Click opens the article on EUR-Lex. and (4) (Art. 12(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex.). Where a responsible person exists, it regularly checks that the product still meets Art. 9(5)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 5Click opens the article on EUR-Lex., (6) and (7), where appropriate to the risks, and must be able to produce documented evidence of those checks (Art. 16(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex.). Who may hold that role is the EU Responsible Person.

The same content appears a second time, in the offer. Any warning or safety information that goes on the product, on the packaging or in an accompanying document must be shown clearly and visibly in a distance-sales offer, in the language the EU country sets (Art. 19(d)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (d)Click opens the article on EUR-Lex.). A provider of an online marketplaceArt. 3(14)a provider of an intermediary service using an online interface which allows consumers to conclude distance contracts with traders for the sale of productsClick the term for the full definition has to give its traders a way to supply exactly that (Art. 22(9)(d)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9, point (d)Click opens the article on EUR-Lex.).

If the instructions are missing

The distributor stops first. It must not make the product available where it has reason to believe Art. 9(7)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 7Click opens the article on EUR-Lex. or Art. 11(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 11, paragraph 4Click opens the article on EUR-Lex. is unmet, until the product is brought into conformity (Art. 12(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 12, paragraph 3Click opens the article on EUR-Lex.). If it has already sold it, it informs the manufacturer or importer and makes sure corrective measures are taken, withdrawal or recall included (Art. 12(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 12, paragraph 4Click opens the article on EUR-Lex.). Storage and transport conditions that damage the instructions are its problem too (Art. 12(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 12, paragraph 2Click opens the article on EUR-Lex.).

Then the offer. An empty warnings field is a visible gap on the listing under Art. 19(d)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (d)Click opens the article on EUR-Lex., and the marketplace was obliged to give you that field (Art. 22(9)(d)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9, point (d)Click opens the article on EUR-Lex.).

Penalties are national. Each EU country lays down the rules on penalties for infringements of this Regulation and takes the measures needed to implement them; the Regulation asks only that they be effective, proportionate and dissuasive (Art. 44Regulation (EU) 2023/988, General Product Safety RegulationArticle 44Click opens the article on EUR-Lex.). What each country sets is GPSR fines.

What you can skip