GPSR on Shopify: what your product page has to show

A Shopify store is your own shop, not a marketplace’s. Nobody hands you a GPSR box to fill in. The information goes on the product page itself, and the law puts the duty on you (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.).

The law’s standard is “clearly and visibly” in the offer (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.). Shopify’s disclosures page says the same in its own words: warnings generally need to be easily accessed and viewed before a purchase is made, for example on the product page. Shopify’s GPSR page lists the identifying element, the manufacturer, the EU responsible person and the warnings as one list for “labels and website”. The law splits that list in two: what is on the product and with it is GPSR labelling requirements, and what is in the offer is the table above.

Shopify’s GPSR page was read on 5 October 2026 and carries no edit date. It says its content is not legal advice. Where it and the Regulation differ in a word, the Regulation wins.

What Shopify does and does not do about GPSR

Shopify does these things:

• It publishes a GPSR help page that sums up the requirements and points to its tools. For warnings it points to the Disclosures metafield and metaobject entries. For everything else it says to use the product description or a metafield.
• It shows a disclosure on your online store’s product pages once your theme is set up for it, on the cart page if you choose that, in the Shop app, and to third-party sales channels and apps through its APIs.
• It lets you set, for each disclosure, the countries or regions where it must be displayed.
• It states, in its Terms of Service, that you are responsible for your store, the goods you sell, “required legal disclosures” and regulatory compliance.

Shopify does not do these, on the two GPSR pages above:

• It does not offer an EU responsible person service directly. Its GPSR page says third-party tools might be available in the Shopify App Store.
• It does not tell you which warnings or which details your product needs.
• It names no check, and no penalty of its own, for a missing item.

Your own Shopify store is not an online marketplace under GPSR

The marketplace duties in GPSR attach to a provider of an online marketplace: a provider of an intermediary service using an online interface that allows consumers to conclude distance contracts with traders for the sale of products (Art. 3(14)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 14Click opens the article on EUR-Lex.). That provider registers with the Safety Gate Portal, names contact points, acts on a takedown order within two working days, and builds an interface that lets traders supply the Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. information (Art. 22(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 1Click opens the article on EUR-Lex., Art. 22(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 4Click opens the article on EUR-Lex., Art. 22(9)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9Click opens the article on EUR-Lex.). Those duties are not yours as the owner of a store that sells your own goods.

Shopify says the same about itself. Its Terms of Service, last updated on 1 August 2026 and read on 5 October 2026, say the Services are not a marketplace, that a contract of sale made through them is directly and only between you and the customer, and that you are the seller or merchant of record.

What that does not remove is Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.. It binds the 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 who make products available online, and your store is the offer (Art. 3(13)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 13Click opens the article on EUR-Lex., Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.). Nothing in Shopify’s GPSR pages asks you to submit anything to Shopify. The page itself is the Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. compliance.

The Regulation names no platform. Its recital 46 says an entity that provides only online intermediation for a product is a marketplace provider for that product, and one that sells its own branded products acts as a manufacturer (recital 46). The Commission’s FAQ says the same in practice: a business’s status follows the concrete service it provides for a given listing. Neither the Regulation nor the FAQ names Shopify, or any other store-building platform. Whether a regulator would ever class a platform’s merchant Services under Art. 3(14)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 14Click opens the article on EUR-Lex. is not answered in either, and it does not change what you owe as the seller (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.).

Two edges. A store that lets other traders sell to consumers through it, a multi-vendor shop, is described by Art. 3(14)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 14Click opens the article on EUR-Lex., and then Art. 22Regulation (EU) 2023/988, General Product Safety RegulationArticle 22Click opens the article on EUR-Lex. is yours, apart from the parts a micro or small enterprise is exempt from under the Digital Services Act (Commission GPSR FAQ). And Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. asks information society service providers to cooperate with market surveillance authorities, at their request, in specific cases (Art. 7(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 7, paragraph 2Click opens the article on EUR-Lex.). That is a duty on the platform. It does not move your Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. duty onto it.

Shopify’s Shop app is a different case, and an edge. Its consumer terms let shoppers buy from many merchants inside Shop, with Shopify not a party to the sale (Shop app terms, s. 2.1.1 and 9.2). That is the shape Art. 3(14)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 14Click opens the article on EUR-Lex. describes: an online interface that lets consumers conclude distance contracts with traders. The Terms line that the Services are not a marketplace covers the merchant Services, not Shop. No source read says how a regulator would treat Shop. If it counts, the Art. 22Regulation (EU) 2023/988, General Product Safety RegulationArticle 22Click opens the article on EUR-Lex. duties for an offer shown in Shop sit with Shopify, not with you. Your Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. duty stays the same either way.

Markets, currency and domains are the signals the law looks at

Your store is subject to GPSR when your offer is targeted at consumers in the Union (Art. 4Regulation (EU) 2023/988, General Product Safety RegulationArticle 4Click opens the article on EUR-Lex.). Recital 21 lists what a case-by-case analysis looks at: the countries you can dispatch to, the languages of the offer and the order, the means of payment, the currency of an EU country, and a domain name registered in an EU country. Merely being reachable from an EU country is not enough. Shopify’s Markets let you set several of those things for a market made of countries: local currency, a domain or subfolder, and a language. A market that includes an EU country and prices in euros ticks two of those boxes. Where your own store falls is worked through on the page on whether GPSR applies to you.

Northern Ireland is inside the same rule. The UK government states that Regulation (EU) 2023/988Regulation (EU) 2023/988, General Product Safety RegulationThe whole regulationClick opens the law on the EU Publications Office. applies in Northern Ireland from 13 December 2024.

How to show the warnings with the Disclosures field

Shopify’s Disclosures field is the one place Shopify built for legally required warnings. It works in three parts, in Shopify’s own order:

1. Create or choose a Disclosures metaobject entry. Each has a title, content, a symbol, a Jurisdictions field for the countries or regions where it must be shown, and display preferences for the product page and the cart page.
2. In the Shopify admin, open the product and pick the entry in the Disclosures field under Product metafields.
3. Connect it to your theme. A Horizon theme takes a Disclosures theme block in the Product information section. An Online Store 2.0 theme such as Dawn takes a Disclosures section on the product page template. For a theme that cannot display it, Shopify names a code snippet as the fallback.

Three limits matter for GPSR.

• Show it before the sale. If a customer can add a product to the cart without opening its page, for a quick-add button or an unlisted add-on, Shopify’s page says to select Cart in the disclosure’s display preferences, so it shows on the cart page too.
• It does not travel in product feeds. Shopify says disclosures made this way are not in contextual product feeds for sales channels. An offer on another channel still has to carry the Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. information (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.). What each marketplace asks for is GPSR marketplace requirements.
• The content is yours. Shopify’s two examples cite California Proposition 65 and a US federal rule on choking hazards, 16 CFR Part 1501. Its page says you are responsible for confirming that a standard entry suits your product and that the warning complies with the law where you sell. What an EU warning has to say is whatever goes on the product or with it under GPSR or the product’s own EU law (Art. 19(d)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (d)Click opens the article on EUR-Lex.), and GPSR labelling requirements sets out what that is.

The language is the Regulation’s rule: a language consumers can easily understand, as determined by the EU country where the product is made available (Art. 19(d)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (d)Click opens the article on EUR-Lex.). A warning written only in English reaches only the countries that accept English. Shopify’s help pages do not say whether Disclosures entries can be translated. What the Disclosures page does document is the Jurisdictions field, so one way to cover several languages is one entry per language, each set to the countries where it shows.

Shopify says Disclosures set up this way show automatically on a product’s page in the Shop app from version 2.239.0 on iOS or Android, and are available to third-party sales channels through the Storefront API and to third-party apps through the Admin API. It also says that if you have already published warnings in descriptions, titles, custom metafields or tags, you should consider removing the old version once the Disclosures field is live.

A Shopify store needs an EU responsible person, and Shopify does not supply one

A product covered by GPSR may not be placed on the market unless an economic operator 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.). Who that can be is listed in Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex.: a manufacturer based in the EU; an importer, where the manufacturer is not based in the EU; an authorised representative holding a written mandate from the manufacturer; or, only where none of those is based in the EU, a fulfilment service providerArt. 3(12)any natural or legal person offering, in the course of commercial activity, at least two of the following services: warehousing, packaging, addressing and dispatching, without having ownership of the products involved ...Click the term for the full definition based in the EU, for the products it handles.

Put your own name or brand on a product and you are its manufacturer (Art. 13(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex.). If you resell somebody else’s branded goods, you are a distributor, and before you offer a product you must verify that its maker and any importer put the required name, address, identifier and instructions on it (Art. 12(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex.). Which role is yours is what GPSR requires of you, by role. A store that ships from outside the EU does not lose the rule: the offer decides it (Art. 4Regulation (EU) 2023/988, General Product Safety RegulationArticle 4Click opens the article on EUR-Lex.).

Shopify’s GPSR page says it does not currently offer a service for designating an EU responsible person, and that third-party tools might be available in the Shopify App Store. The test for any of them is the one in Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.. The condition is met by an operator based in the EU that holds the Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. tasks for your product. A tool that only prints fields on your product page is software, not an operator, and does not meet it. Whoever you name goes on the page as the Art. 19(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (b)Click opens the article on EUR-Lex. item and on the product as the Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex. item. Who is eligible, and what the market charges where nobody in your chain qualifies, is the EU Responsible Person.

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 on the page the same way (Art. 19(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (b)Click opens the article on EUR-Lex.). Which rule covers your product is on the EU Responsible Person.

Shopify’s Managed Markets turns Global-e into the merchant of record for the orders it handles, and Shopify’s page says Global-e takes on duties, tax remittance, commercial invoices and carrier arrangements. That page does not mention GPSR. GPSR names its roles by what a business does with the product: manufacturer, authorised representative, importer, distributor and fulfilment service provider (Art. 3(8)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 8Click opens the article on EUR-Lex. to Art. 3(13)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 13Click opens the article on EUR-Lex.). Merchant of record is not among them.

On a Managed Markets order Global-e is the legal seller and the shopper is the importer of record (Global-e Service Terms, s. 1.3 and 3.5). An importer under Art. 3(10)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 10Click opens the article on EUR-Lex. is a person based in the EU who places a product from a third country on the Union market. A consumer importing for their own use is not that, so the importer step of the cascade yields nobody. The Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. operator has to be an EU manufacturer, an authorised representative with a written mandate, or, where none of those is based in the EU, an EU fulfilment service provider. The terms read are the US version, and Shopify says Managed Markets is available to businesses based in the continental United States and to certain stores in Canada and the United Kingdom.

Recalls and accidents on a Shopify store

When a manufacturer considers, or has reason to believe, that a product it placed on the market is dangerous, it takes the corrective measures needed, including a withdrawal or a recall, informs consumers, and informs the market surveillance authorities of the EU countries where it was sold, through the Safety Business Gateway (Art. 9(8)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 8Click opens the article on EUR-Lex.). A distributor tells the manufacturer or the importer and sees that the same is done (Art. 12(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 12, paragraph 4Click opens the article on EUR-Lex.).

Your store is where the buyers are. Operators that collect their customers’ personal data must use it to tell all affected consumers they can identify, directly and without undue delay (Art. 35(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 35, paragraph 1Click opens the article on EUR-Lex.). A store collects names and contact details at checkout, so the order records are that data. Where not all of them can be reached, you put a clear and visible notice on other channels, and the Regulation names your own website first among them (Art. 35(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 35, paragraph 4Click opens the article on EUR-Lex.). A manufacturer must also give consumers a public way to report a complaint or an accident, such as an electronic address or a section of its website (Art. 9(11)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 11Click opens the article on EUR-Lex.).

An accident that caused a death or serious harm to health is a separate notification to the authorities of the country where it happened (Art. 20(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 20, paragraph 1Click opens the article on EUR-Lex., Art. 20(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 20, paragraph 2Click opens the article on EUR-Lex.). Where the manufacturer is outside the Union, the responsible person ensures it is made (Art. 20(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 20, paragraph 4Click opens the article on EUR-Lex.). Who you notify, what the recall notice says word for word, and what remedy you owe are in product recall under GPSR.

Switching off EU sales on Shopify

Shopify lets you remove a country or region from a market, or deactivate a whole market. Customers in an inactive market cannot complete a purchase, and orders already placed are not affected. Shopify’s Markets pages name countries and regions and do not mention Northern Ireland, which GPSR covers. Etsy’s own shop-level opt-out, and what it does to the shop’s visibility, is set out on GPSR on Etsy.

What happens if the product page stays bare

No marketplace sits between you and the authority, so no marketplace pulls the offer first. Shopify’s GPSR and Disclosures pages name no consequence of their own. Its terms say you represent and warrant that you will comply with applicable laws. For a product that presents a serious risk, the authority can order the content removed and, if that is not done, order the host to restrict access to your store (Art. 14(4)(k)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 14, paragraph 4, point (k)Click 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., applied by Art. 23(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 23, paragraph 1Click opens the article on EUR-Lex.). Fines are national: GPSR sets no figure itself, each EU country lays down the penalties, and 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 actually sets is GPSR fines.

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