GPSR marketplace requirements: the field you have to fill

That split is why the box appeared on your listing form. Whatever the marketplace calls it, it asks for an EU contact for the product, named because the maker sits outside the Union (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 four things the field asks for

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 and organise its online interface so that traders can provide, for each product offered, the information in Art. 22(9)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9Click opens the article on EUR-Lex., and must make sure that information is displayed or otherwise made easily accessible to consumers on the product listing. The four items are the same four Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. asks of you directly:

• (a) the name, registered trade name or registered trade mark of 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, and the postal and electronic address at which the manufacturer can be contacted;
• (b) where the manufacturer is not EU-based, the name, postal and electronic address of the responsible person meant by Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. of GPSR or by Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click 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.;
• (c) information allowing the identification of the product, including a picture of it, its type and any other product identifier;
• (d) any warning or safety information to be affixed on the product or to accompany it, in a language consumers can easily understand, picked by the EU country where the product is made available on the market.

The platform also has to run internal processes that let traders hand over that information, and give their self-certification committing to offer only products that comply (Art. 22(10)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 10Click opens the article on EUR-Lex.).

And it has to 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.).

Why your own address does not take you out of it

Art. 4Regulation (EU) 2023/988, General Product Safety RegulationArticle 4Click opens the article on EUR-Lex. settles it in one sentence. Products offered for sale online or through other means of distance sales are deemed to be made available on the market if the offer is targeted at consumers in the Union, and an offer counts as targeted where the 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 directs its activities, by any means, to one or more EU countries. Shipping is not the trigger. Targeting is. Where that leaves your particular product is worked through on the page on whether GPSR applies to you.

The field is not a marketplace invention either. 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 EU-based economic operator 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.), and that operator’s name, registered trade name or registered trade mark and contact details, including the postal and electronic address, must be indicated on the product or on 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.). Who may hold that role, and what it costs, is in the EU Responsible Person guide. 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 the field 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 the platform used a term you did not expect, the three roles businesses get asked for are told apart in the EU authorised representative guide.

What Amazon, Etsy and eBay call the field

Each marketplace wrote its own label. The legal content behind all three is Art. 22(9)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9, point (b)Click opens the article on EUR-Lex.: an EU-based contact for the product, named where the manufacturer sits outside the Union. Marketplace policy changes without notice.

Amazon’s public announcement tells sellers it is mandatory to have a Responsible Person established in the EU for non-food products, with that contact information on the label in one of the EU’s official languages. Amazon’s detailed GPSR help pages sit in Seller Central and open only to signed-in sellers. Etsy’s field is the only one at shop level; Amazon’s and eBay’s are filled per product. Etsy says one route is enough for its own form: “You only need to fill either the shop-level or the listing-level field to meet GPSR requirements”. The law still needs the manufacturer’s details, and a non-EU manufacturer’s responsible person, visible in each offer (Art. 19(a)-(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, points (a) to (b)Click opens the article on EUR-Lex.).

Selling on a store of your own is a different case: there is no marketplace field to fill, and the product page itself has to carry the details. That is GPSR on Shopify.

What other EU marketplaces call the field

Every provider of an online marketplace carries the same Art. 22(9)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9Click opens the article on EUR-Lex. duty, so every one of them has a field. The names differ again:

What goes in the field and what goes on the product are two separate duties, and they are easy to run together. The marking, the instructions and the safety information are in GPSR labelling requirements. Which role you hold for the product, and therefore whose details belong in the manufacturer box, is worked out in what GPSR requires of you, by role.

What happens if you leave the field empty

The marketplace acts first: it pulls the listing, hides it from EU buyers, or blocks the sale. The regulator comes later, if at all. Each platform sets out its own consequence in its own words.

• Amazon, in the announcement posted by a staff account in its public Seller Forums: “Non-compliant listings risk removal and ineligibility for flash sales.”
• eBay, on its Seller Center GPSR page: “If you don’t comply with the GPSR, your listings may not be visible or purchasable to buyers in the EU and Northern Ireland.” The same page says visibility comes back once the required information is provided.
• Etsy names no penalty for the empty field itself. Its Seller Handbook says what follows an authority’s notice: “Should Etsy receive notification from an authority that your product is non-compliant, we’ll take appropriate action, which may include removing your listing and/or suspending your account.” Its help page also offers an opt-out: “You can opt out of selling your products to GPSR countries. Once you opt out, buyers in EEA States and Northern Ireland won’t be able to purchase items from your shop.”

Underneath all three sits Art. 22(11)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 11Click opens the article on EUR-Lex.: a marketplace must suspend its services, after a prior warning, to traders that frequently offer non-compliant products. That is the floor the Regulation sets for the platform, not a promise about how any one of them enforces it.

The regulator’s consequence is national, and it is slower. 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 in the GPSR fines guide.

How to find the operator you name in the field

The route that costs nothing comes first. 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 EU-based 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 is already in your chain, the condition is met and there is nothing to buy: an EU subsidiary that manufactures, an EU importer, meaning the business that places your goods on the EU market and not merely the customs broker that declares them (importer of record), or 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 does it. What is left is putting that operator’s details on the product (Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.) and into the marketplace’s field (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.). The full test of who is eligible is in the EU Responsible Person guide, and no marketplace decides it.

Paid help buys one thing: an EU-based operator willing to take the Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. tasks under a written mandate for your products. It does not buy a certificate, and no marketplace requires a particular provider. Each field is filled per marketplace, from the same set of details, so one appointment can serve every channel you sell on.

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