GPSR on eBay: what goes in Item disclosures

Item disclosures works the same in a new listing and in a revision. Three toggles live there - Product manufacturer, Product Safety and Product documents - and what you type into them is what buyers in the EU and Northern Ireland see on the listing.

What eBay asks for

From eBay’s Seller Center page on the General Product Safety Regulation, in eBay’s own words:

“To comply with the GPSR and related regulations, all business sellers listing items for sale in the EU and NI must include the following information: The product manufacturer’s name and contact information[;] If the manufacturer isn’t located in the EU or NI, you’ll have to indicate an EU-based Responsible Person or entity, along with their name and contact details[;] Any relevant product information like model number, pictures, and type[;] Product safety and compliance information like warnings and safety information (which can be included in labels and product manuals) in the local language[;] The CE marking when required by the related regulations applicable to your product.”

That is Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. in eBay’s vocabulary. The Regulation asks a distance offer to carry the manufacturer’s name and postal and electronic address, the responsible person where the manufacturer is not EU-based, information identifying the product including a picture of it, and any warning or safety information in a language consumers can easily understand in the EU country where the product is sold.

You type that information into Item disclosures, and eBay shows it on the listing. 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 must design its interface so traders can supply at least that information for each product offered, and display what they supply (Art. 22(9)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9Click opens the article on EUR-Lex.). That duty in full is on the GPSR guide and in GPSR marketplace requirements.

Where the fields are

Item disclosures, in a new listing or a revision. eBay gives the click path twice, once for the contacts and once for the safety information. For contacts, from eBay’s help page on regulatory contacts and responsible parties:

“Create a new listing or revise an existing listing. Go to the Item disclosures section. Select the toggle next to Product manufacturer. Click + Add Product manufacturer to add contact information. If your Product manufacturer is not based in the EU or Northern Ireland, you can also click + Add EU responsible person to add contact information.”

“You can add up to five EU responsible persons.”

For the safety information, from eBay’s product safety disclosures page:

“Create a new listing or revise an existing listing. Go to the Item disclosures section. Select the toggle next to Product Safety. Choose up to 4 Pictograms and/or up to 8 Statements. You can also add Additional information (120 characters).”

“Sellers can upload up to 10 product documents, per listing, to comply with GPSR requirements. Documents can be in .pdf, .jpg or .png format, and sellers can specify multiple languages for each document.”

The same pages add two practical details. Both fields can also be filled in bulk, through Bulk edit and then Item disclosures. The Additional information box does not take a web address: eBay says it “does not support URLs”.

These are eBay’s published help pages. The listing form itself opens only inside a seller account. None of the three eBay pages carries a last-updated date.

eBay says what the safety block is for:

“Displaying product safety information in your listings provides buyers with clear information about the product risk and can help them make an informed buying decision. Product safety information might include, for example, the presence of button batteries or coin batteries or suitability of the product for children under three.”

Filling these boxes is not the same duty as marking the item. The responsible operator’s details also go on the product, its packaging, the parcel or an accompanying document (Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.); the label and the instructions are GPSR labelling requirements.

What eBay means by “EU responsible person”

eBay’s definition, on the same help page:

“An EU Responsible Person is a type of economic operator which is established in the EU. It is the entity in the EU who is responsible for certain tasks related to compliance and product safety.”

That matches the Regulation. A product covered by GPSR may not be placed on the marketArt. 3(7)the first making available of a product on the Union marketClick the term for the full definition unless an economic operatorArt. 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 based in the EU is responsible for the tasks in Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. for that product (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.).

It is not a licence you must buy, and it is not eBay’s to approve. Who is eligible is the EU Responsible Person, and the three roles that get confused with each other are separated in EU authorised representative. Whose details belong in the Product manufacturer box depends on which role you hold for the item: what GPSR requires of you, by role.

For a toy, an electrical or radio product, machinery or protective equipment, GPSR Art. 16Regulation (EU) 2023/988, General Product Safety RegulationArticle 16Click opens the article on EUR-Lex. does not apply (Art. 2(1)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1, point (b)Click opens the article on EUR-Lex.). Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. asks for the same EU company instead (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex.), and its details go in eBay’s EU responsible person box the same way (Art. 19(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (b)Click opens the article on EUR-Lex., Art. 22(9)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9, point (b)Click opens the article on EUR-Lex.). Which rule covers your product is on the EU Responsible Person.

If you leave the fields empty

Already filled it in and still blocked? That is a different problem: what keeps a listing down after you send your details.

eBay’s answer is about visibility, not money. On what happens to a listing left incomplete:

“If you don’t comply with the GPSR, your listings may not be visible or purchasable to buyers in the EU and Northern Ireland.”

“In the case of missing GPSR information for specific listings, your listings may not be visible or purchasable to buyers in the EU and Northern Ireland. Impacted listing(s) will have visibility restored when the required GPSR information is provided, unless there are other reasons the listing is hidden. There shouldn’t be any impact to that listing’s history or search ranking.”

“There shouldn’t be GPSR-related action at an account level, unless a relevant amount of listings will be identified as non-compliant or a seller repeatedly violates requirements after suitable warnings.”

eBay puts that first line in the context of sellers who keep shipping to the EU and Northern Ireland without updating their listings.

An eBay community team member described the same mechanic for cross-border sellers in a public forum thread:

“eBay eIS will not surface items which are not compliant in the EU and Northern Ireland. Also, for Passive CBT (Cross Border Trade) sellers from non-EU sites: the Manufacturer/RP (Responsible Person) on non-EU sites (i.e. US, AU, etc.) won’t be mandatory in the listing flow, but listings without these info won’t be displayed on the EU sites for categories where we mandate them.”

eBay publishes no list of the categories where it mandates the fields. It also does not say how it treats a listing that carries the details only in the description; every eBay page quoted here names the Item disclosures fields as the place for them. So fill the fields for every item you ship to the EU or Northern Ireland.

The account-level caveat is the Regulation showing through: a marketplace must suspend, for a reasonable period and after a prior warning, its services to traders that frequently offer non-compliant products (Art. 22(11)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 11Click opens the article on EUR-Lex.).

The law’s own consequence is separate and national. GPSR sets no figure itself: each EU country lays down the rules on penalties for infringements and takes the measures needed to implement them, and the Regulation requires 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 actually sets is GPSR fines.

Who can fill it for you

Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. is a condition on the product, not a purchase. If an economic operatorArt. 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 based in the EU is already in your chain, their name and address are what goes into eBay’s box. An EU subsidiary that manufactures, an EU importer of record, an EU business already holding a written mandate for the Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. tasks: any of those meets the condition, and nothing is bought. eBay takes up to five entries per listing. Where nobody in your chain qualifies, what the market charges is on the EU Responsible Person.

The rest of the eBay work is yours to write and costs nothing but time: pictograms, statements, the 120 characters, the documents. It is a labelling and instructions job, not a service anybody has to sell you.

What you can skip