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GPSR product page check sheet: does every listing in your web shop show the manufacturer, EU responsible person, picture, identifier and warnings? (Article 19)

Updated 27 Oct 2026 · Disclosure: the two Apify Actors mentioned below are built and published by Unadhi. Legal facts come only from the GPSR text on EUR-Lex, the Commission's GPSR guidelines and the other official pages listed in Sources, all read on 27 Oct 2026. This guide is for information only, not legal advice.

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What you get: a finished GPSR product page check sheet in three tabs: a listings tab with one row per product in your web shop and a result formula that names exactly which of the four Article 19 items, (a) to (d), is missing on that page; a manufacturers tab with one row per brand (legal name, postal address, electronic address, EU responsible person, source page); and a countries and languages tab for safety warnings. Four made-up example rows show how it fills in.

Short answer: since 13 December 2024 (GPSR Article 52), when you sell consumer products online to people in the EU, the offer "shall clearly and visibly indicate at least" four things (Article 19): (a) the manufacturer's name, registered trade name or trade mark and the "postal and electronic address at which they can be contacted"; (b) if the manufacturer is not established in the EU, the name, postal and electronic address of the EU responsible person; (c) information identifying the product, "including a picture of it, its type and any other product identifier"; and (d) any warning or safety information, in a language consumers can easily understand as set by the Member State where you sell. The Commission's guidelines repeat the same list for "a product offer on your e-shop" (C/2025/6233, Official Journal 21 November 2025).

The pain this page is about

"I have 600 products from 40 brands. Which pages are missing the manufacturer's address, and which brands are made outside the EU and need a responsible person shown?" Opening every page by hand takes days. Exporting every product into one sheet and adding a few Y/N columns takes an afternoon.

Step 1: export every product page into one sheet

Run our Shopify & WooCommerce Product + Price Tracker on your shop's homepage or category pages. It returns one row per product with url, title, brand, sku/gtin, images and the description as plain text, which become columns A to F below. The Actor checks robots.txt and the shop's terms first and skips (without charge) any shop whose terms forbid scraping; many Shopify shops keep Shopify's default terms, which do. If its SHOPS_SUMMARY row shows your shop as skipped, use your shop's own product export instead: Shopify · WooCommerce. The sheet works the same.

Step 2: tab 1, listings (one row per product page)

ColumnWhat to writeSource
A. Product URL, B. Title, C. BrandFrom the export (url, title, brand)
D. Type and identifier shownY if the page shows the type or model and an identifier such as SKU, GTIN/EAN, model or batch number; N if not. The export's sku and gtin tell you what you hold, but check the identifier is visible on the pageArt. 19(c); Art. 9(5)
E. Picture shownY if the export's images field is not empty and the photo shows this product. Recital 42 says a picture is "a photograph, illustration or other pictographic element"Art. 19(c)
F. Description textFrom the export (description). Used only for the hint in column N
G. Manufacturer name shownY/N: name, registered trade name or registered trade mark of the manufacturer (the brand owner is often, not always, the manufacturer)Art. 19(a)
H. Manufacturer postal address shownY/NArt. 19(a)
I. Manufacturer electronic address shownY/N: email or other electronic contact addressArt. 19(a)
J. Manufacturer established in the EUY/N, from tab 2Art. 19(b)
K. EU responsible person shownY if name, postal and electronic address of the EU responsible person are on the page; N if not; leave blank if J is YArt. 19(b); Art. 16(1)
L. Warnings or safety info exist for this productY if a warning or safety information has to be on the product, its packaging or an accompanying document (for example on the box or in the leaflet); N if noneArt. 19(d); Art. 9(7)
M. Warnings shown in the right language(s)Y/N, using tab 3 for each country you sell toArt. 19(d)
N. Hint from the description=IF(SUMPRODUCT(--ISNUMBER(SEARCH({"manufacturer","hersteller","fabricant","fabbricante","fabricante","producent","tillverkare","valmistaja"},F2)))>0,"word found: check G-I","no manufacturer word: likely missing")A hint only, not proof: details may sit in a tab or block the export does not read
O. Result=IF(TEXTJOIN(", ",TRUE,IF(OR(G2<>"Y",H2<>"Y",I2<>"Y"),"(a) manufacturer",""),IF(AND(J2="N",K2<>"Y"),"(b) EU responsible person",""),IF(OR(D2<>"Y",E2<>"Y"),"(c) picture, type, identifier",""),IF(AND(L2="Y",M2<>"Y"),"(d) warnings",""))="","OK: all four Article 19 items shown","FIX: "&TEXTJOIN(", ",TRUE,IF(OR(G2<>"Y",H2<>"Y",I2<>"Y"),"(a) manufacturer",""),IF(AND(J2="N",K2<>"Y"),"(b) EU responsible person",""),IF(OR(D2<>"Y",E2<>"Y"),"(c) picture, type, identifier",""),IF(AND(L2="Y",M2<>"Y"),"(d) warnings","")))Formula and labels are our working rule, not a legal test. TEXTJOIN works in Google Sheets and Excel 2019 or later

Note on (a) and (b): if the manufacturer is outside the EU, the page needs both the manufacturer's details and the responsible person's. In a September 2024 reply to Toy Industries of Europe, Commission staff wrote that "the requirements under Article 19 (a) and (b) are to be read as cumulative" (a service-level reply, not an official interpretation; see Sources). The formula already treats them that way.

Step 3: tab 2, manufacturers (one row per brand)

ColumnWhat to write
A. BrandAs in tab 1, column C
B. Manufacturer nameName, registered trade name or registered trade mark
C. Postal addressLook on the product or its packaging first: Article 9(6) says the manufacturer must put its name, trade name or trade mark and postal and electronic address there, or in an accompanying document. Otherwise copy it from the brand's legal notice or imprint page
D. Electronic addressEmail or other electronic contact
E. Source page and date checkedWhere you found C and D, and when
F. Established in the EUY/N
G. EU responsible personIf F is N: name, postal and electronic address. Article 16(3) says these details go on the product or its packaging, the parcel or an accompanying document, so check the box and delivery note first, then ask your supplier

For 40 brands, column D is the slow part. Our Website Contact Scraper takes a list of brand websites and returns one row per site with the role emails (info@, support@) and phone numbers that site publishes, each with the page it was found on, and it reads contact, about and impressum pages first. It does not return postal addresses: copy those by hand from the source page it gives you.

Step 4: tab 3, countries and languages

ColumnWhat to write
A. Country you ship toEvery EU country your shop delivers to
B. Language(s) for warningsAs "determined by the Member State in which the product is made available" (Art. 19(d)). Check each country's rule; we do not list them here
C. Warnings on your pages in that languageY/N. Feeds tab 1, column M

Are you selling to EU consumers at all? An online offer counts if it is "targeted at consumers in the Union" (Article 4). The Commission lists factors for that case-by-case test: where you dispatch to, the languages used, the payment methods, and use of a Member State's currency or domain name (Guidelines, section on sales channels). Shops outside the EU that ship to the EU are covered.

Made-up example (four rows, tab 1 results only)

Product (made up)What the page showsResult
Beeswax candle, brand made in GermanyMaker name, address, email, photo, SKU, burn warning in GermanOK: all four Article 19 items shown
Wooden toy car, brand made in ChinaMaker name and address, photo, EAN; no EU responsible person; age warning only in the photo of the boxFIX: (a) manufacturer, (b) EU responsible person, (d) warnings (here: email missing, no responsible person, warning not on the page)
Ceramic mug, own labelPhoto and title onlyFIX: (a) manufacturer, (c) picture, type, identifier
Phone case, brand made in SpainMaker name, address, email, photo, model number; no warning neededOK: all four Article 19 items shown

These rows are invented to show the formula. They are not real products or shops.

Try it on one category first

Free gift: copy-paste input for one category

{ "startUrls": [{ "url": "https://your-shop.example/collections/toys" }], "maxProductsPerShop": 200, "maxListingPages": 5, "includeDescription": true }

Replace the URL with one of your own category pages. Related sheets for EU shops: 30-day lowest price log for Black Friday · Google Shopping listing check · checkout accessibility sheet.

Frequently asked questions

Since when does Article 19 apply?

The GPSR applies from 13 December 2024 (Article 52).

Can I show only the EU responsible person for a non-EU brand?

No. Article 19(a) asks for the manufacturer's details in every case, and 19(b) adds the responsible person when the manufacturer is outside the EU. Commission staff called the two "cumulative" in a 2024 reply (not an official interpretation).

Does this cover marketplaces?

If you sell on a marketplace, Article 22(9) requires the marketplace to design its interface so that traders can enter the same information and to show it on the product listing. This sheet is built for your own web shop pages.

Is passing this sheet enough for GPSR?

No. Article 19 is one duty. The GPSR also covers safety by design and risk analysis (Article 9), the responsible person's checks (Article 16) and accident notification (Article 20), among others.

Not legal advice. The result formula only checks whether information is shown, not whether it is correct or whether the product is safe. Product-specific EU laws (toys, electrical goods, cosmetics and others) can add more labelling rules. When in doubt, ask your national market surveillance authority or a lawyer. Spotted an error? Write to mininglife7@gmail.com and we correct it.

Sources

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Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.