Since 13 December 2024 (Regulation (EU) 2023/988, EUR-Lex) the EU General Product Safety Regulation, GPSR for short, has applied directly in every member state. No national implementing act, no grace period for offers already online. For online shops the practically most important part sits in a single article: Article 19 requires every individual product offer to carry four (Regulation (EU) 2023/988, Article 19) pieces of information clearly and visibly. With the new German Product Safety Act, in force since 19 February 2026 (ProdSG, BGBl. I 2026 No. 29), several long-disputed points have been settled, above all the question of whether the registered company name is required or the trade mark suffices. This article translates the legal text into shop work: which four details belong where, how to maintain them cleanly in the data model instead of as body copy in the description, why listing, search and feed must show the same values, and what a review routine for an existing catalogue looks like. The text is a factual orientation and does not replace individual legal advice.
What the GPSR Actually Requires in an Online Shop
The GPSR replaced the old Product Safety Directive 2001/95/EC and, being a regulation, applies directly without a German act first casting it into national law (Regulation (EU) 2023/988, EUR-Lex). It covers consumer products made available on the EU market, as far as no more specific product law already governs the same aspect. For online retail its reach is wider than many operators assume: the obligations hit not only large platforms but every economic operator offering products to consumers in the EU through distance selling. That includes a manufacturer's own shop just as much as a retailer's shop with a few hundred articles. As with the GDPR checklist for websites, the duties attach to the activity, not to company size. German online retail turned over 83.1 billion euros (bevh) in goods in 2025, up 3.2 percent (bevh) year on year, and 56 percent (bevh) of that ran through marketplaces. Anyone selling there and in their own shop in parallel has to keep the details consistent across both channels.
That product safety is no fringe topic is shown by the European rapid alert system Safety Gate. Authorities registered 4,671 (European Commission, Safety Gate report 2025) alerts in 2025, the highest figure since the system started in 2003 and an increase of 13 percent (European Commission, Safety Gate report 2025). These triggered 5,794 (European Commission, Safety Gate report 2025) follow-up actions by national authorities, up 35 percent (European Commission, Safety Gate report 2025). The most frequently reported categories were cosmetics at 36 percent (European Commission, Safety Gate report 2025), toys at 16 percent (European Commission, Safety Gate report 2025) and electrical appliances at 11 percent (European Commission, Safety Gate report 2025). Chemical risks were the most common reason for an alert at 53 percent (European Commission, Safety Gate report 2025). In Germany the Federal Institute for Occupational Safety and Health is the national Safety Gate contact point and coordinates the exchange of information between market surveillance, the European Commission and the member states (BAuA).
GPSR, ProdSG and market surveillance: who does what
The Four Mandatory Details on Every Product Offer
Article 19 GPSR is short and leaves little room for interpretation. Where an economic operator makes products available online or through another form of distance selling, the offer must carry at least four pieces of information clearly and visibly (Regulation (EU) 2023/988, Article 19). The decisive word is offer: what is meant is the individual product page, not a central information page in the footer. In its FAQ on the product safety regulation, the Chamber of Industry and Commerce for the Stuttgart Region points out that the details must appear in text form in the offer itself and that a mere link to another page or a PDF file does not suffice (IHK Region Stuttgart).
Where an economic operator makes products available on the market online or through other means of distance sales, the relevant offer of those products shall clearly and visibly indicate at least the following information.
Manufacturer details
The name, registered trade name or registered trade mark of the manufacturer, plus the postal address and an electronic address at which they can be contacted. The email address belongs in the offer; on the prevailing reading, a contact form elsewhere does not replace it.
EU responsible person
If the manufacturer is not established in the Union, the offer additionally needs the name, postal address and electronic address of the responsible person within the meaning of Article 16(1) GPSR or Article 4(1) of Regulation (EU) 2019/1020. Without such a person the product may not be offered.
Product identifiers
Information allowing the product to be identified: a picture of the product, its type and further identifiers such as type, model or batch designation. The product image is therefore no longer a purely marketing element but part of the mandatory information.
Warnings
Any warnings and safety information. Section 6 ProdSG explicitly requires the German language for products within the scope of the GPSR (ProdSG, BGBl. I 2026 No. 29); an English manufacturer text taken over unchanged therefore does not meet the requirement.
Two points are regularly overlooked in practice. First, Article 19 applies to existing articles just as it does to new ones: a catalogue built before December 2024 is not privileged by its age as long as the offers are online. Second, a retailer is not off the hook merely because they are not the manufacturer. They have to obtain and display the details; if the supplier does not provide them, that is a sourcing problem, not a justification. Anyone rebuilding their shop anyway should plan the fields in from the start. Which platform decision sits behind that is set out in our article on the question of a Shopware CE shop or a website builder.
What the New ProdSG Has Clarified Since February 2026
The GPSR needed no implementing act, but it did need national flanking: sanctions, language rules and enforcement powers remain a matter for the German legislator. The Act amending the Product Safety Act and further product safety provisions was promulgated on 5 February 2026 (BGBl. I 2026 No. 29) and entered into force on 19 February 2026 (BGBl. I 2026 No. 29). Among other things, it adds 32 (ProdSG, BGBl. I 2026 No. 29, Section 28) administrative offences to the ProdSG. Most of them carry fines of up to 10,000 euros (ProdSG, BGBl. I 2026 No. 29); two breaches of the GPSR can cost up to 100,000 euros (ProdSG, BGBl. I 2026 No. 29) and concern the duty of manufacturers and importers to take corrective action for dangerous products.
| Point | Position until 18 February 2026 | Position since 19 February 2026 |
|---|---|---|
| Manufacturer designation | The old ProdSG knew only the company name, while the GPSR also allowed trade name or trade mark | Name, registered trade name and registered trade mark are equally admissible |
| Language of warnings | Derived from the GPSR: a language easily understood by consumers, without national specification | Section 6 ProdSG explicitly requires the German language for Germany |
| Fines for GPSR breaches | No dedicated national fine provision for the GPSR duties | 32 administrative offences, mostly up to 10,000 euros, two up to 100,000 euros |
| Enforcement towards platforms | Based on general market surveillance powers | Explicit powers, supplemented by requirements for the design of online interfaces |
For shop operators the clarification on the manufacturer designation is the practically most important one. Until the amendment it was disputed whether an offer must name the registered company name of the entity behind it or whether the trade mark suffices: the old ProdSG knew only the company name, whereas Article 19 GPSR expressly places name, registered trade name and registered trade mark side by side. Anyone stating the trade mark alone was potentially exposed. Since 19 February 2026 (ProdSG, BGBl. I 2026 No. 29) the three variants rank equally. The condition remains that the trade mark can be clearly attributed to a responsible economic operator and is supplemented by a postal address and an electronic address. A trade mark without contact details does not meet the requirement.
What this does not change
A Data Model Instead of Free Text in the Description
The most common implementation mistake is not a legal one but a structural one: the mandatory details end up as a paragraph at the bottom of the product description. That works with twenty articles and breaks with two thousand. Free text cannot be checked cleanly, cannot be filtered, cannot be updated via import and cannot be carried reliably into other output channels. If a supplier moves, every affected description would have to be touched individually. A Händlerbund study on the product safety regulation with around 600 (Händlerbund) surveyed merchants shows where it hurts: 74 percent (Händlerbund) named practical implementation as the biggest challenge, 73 percent (Händlerbund) the uncertainty and 71 percent (Händlerbund) the time required. 64 percent (Händlerbund) felt poorly or very poorly informed.
The clean solution is a dedicated field per detail. In a Shopware CE shop you can create custom fields for this and assign them to a product group; the principle applies regardless of the system in use, though.
- One field per detail: manufacturer name or trade mark, manufacturer address, electronic address, EU responsible person, product identifiers, warnings
- Maintain manufacturers as their own entity and link them to the product instead of repeating the same address in every article
- Use inheritance: the parent product carries the details, individual variants override them only where they genuinely differ
- Enforce mandatory fields so that an article without manufacturer details cannot be published in the first place
- Enable maintenance via imports and bulk editing so that a supplier change means one file and not a clicking marathon
- Log changes so that in a dispute it stays traceable since when which detail appeared in the offer
The effort for this data model is incurred once; the effort for free text is incurred again with every change. From our shop projects (project experience), a catalogue with a clean field structure can typically be filled via an import file in a single pass, whereas the same changeover through description texts ties up weeks of manual work. The same logic, mandatory details in dedicated fields rather than in body copy, carries over to other page types too: if a careers page is to win applicants, job details belong in a structured form just as much, rather than typed into a description text. How to structure a catalogue in general so that categories, filters and fields fit together is described in our article on website structure and information architecture.
One field that tends to be forgotten
Listing, Search and Feed: the Same Values Everywhere
Article 19 speaks of the offer, and in a modern shop an offer exists in several places: on the detail page, in category and search views, in the internal search, in the cart and in exported product data for marketplaces or ads. The detail page is where all four details have to appear in full. For list views that does not apply to the same depth, yet that is exactly where contradictions arise: if a tile shows a different trade mark than the detail page, or a feed carries a long-outdated manufacturer name, that is not merely a data error but, in case of doubt, evidence that maintenance is not working.
In practice this means: detail page, listing, internal search and feed should read from the same source. If feeds are built from a separate export sheet that someone updates once a quarter, divergence is pre-programmed. 56 percent (bevh) of goods revenue in German online retail ran through marketplaces in 2025, so the feed is correspondingly often the channel where the error surfaces first. Anyone who additionally makes the details available as filters, for instance by manufacturer or by warning category, gains a review view as a by-product: a filter on articles without manufacturer details is the fastest error list a shop can offer. That structured product data also helps the visibility of the shop in search is a welcome side effect. For completeness: the mandatory details under Article 19 have nothing to do with the information duties around payment methods in an online shop; they merely live on the same page and are therefore readily confused.
Warnings: Using Pictograms and Images Properly
Warnings are the fourth mandatory detail and at the same time the trickiest one in design terms. Under Section 6 ProdSG they have to be available in German in Germany (ProdSG, BGBl. I 2026 No. 29), they have to be visible in the offer, and they are meant to be understood. Many businesses solve this by uploading a photo of the back of the packaging. That is convenient and weak for two reasons: a photo stays mute for screen readers without alternative text, and it is neither searchable nor updatable without producing a new image. Chemical risks were the most common reason for Safety Gate alerts in 2025 at 53 percent (European Commission, Safety Gate report 2025), which is exactly the category where warnings count.
- Maintain warnings as text rather than as image content: text can be read aloud, filtered and changed via import
- Use pictograms as a supplement, for example age labelling or hazard symbols, and embed them as SVG so they stay sharp at any size
- Give every pictogram an alternative text that conveys the message rather than describing the symbol
- Try not to hide safety information behind an accordion that only opens after a click
- Show photos of the packaging at most as a supplement, on no account as the sole carrier of the mandatory detail
- Keep an eye on image weight so that the detail page does not get slower through additional graphics
The silent error with variants
Pictograms and additional graphics increase the weight of the detail page. How to absorb that without a loss of quality is shown in our article on how to optimise images for a website. And if an AI assistant answers product questions in the shop, a second labelling duty comes into play that has nothing to do with the GPSR but concerns the same product page: what to watch out for is described in our article on labelling AI chatbots under the AI Act.
A Review Routine for the Existing Catalogue
A new catalogue can be set up cleanly. The existing stock is the real work, and it can rarely be done in one go. What helps is a routine that prioritises by risk rather than alphabetically: product groups that appear frequently in Safety Gate come first. Cosmetics, toys and electrical appliances together accounted for 63 percent (European Commission, Safety Gate report 2025) of alerts in 2025. Anyone trading in those groups should start there.
- Take stock: export the catalogue with all relevant fields and count how many articles are empty per mandatory detail. That number is the baseline and at the same time the measure of progress.
- Prioritise: start with the product groups that stand out from a market surveillance perspective, and with articles from manufacturers outside the EU, because the EU responsible person may be missing there as well.
- Clarify sources: request missing details from the supplier in a structured way, with a table per field rather than an email per article.
- Fill the data model: import the details into the fields created for them, not into the description.
- Check inheritance: sample-check variants whose warnings differ from the parent product.
- Reconcile output channels: compare detail page, listing and feed for the same articles and clarify every deviation.
- Set a follow-up: fix a date on which the catalogue is checked against the fields again, and record the result.
This routine is not a project with an end date but a recurring appointment. New articles arrive, suppliers change, manufacturers move. Anyone planning the review as a fixed part of ongoing website care spreads the effort across small portions instead of one night shift after the first warning letter. The wider frame this fits into is set out in our overview of the e-commerce trends for 2026.
Where the Risk Actually Sits
The spectacular numbers are in the ProdSG: up to 100,000 euros (ProdSG, BGBl. I 2026 No. 29) for two GPSR breaches, up to 10,000 euros (ProdSG, BGBl. I 2026 No. 29) for the remainder of the 32 (ProdSG, BGBl. I 2026 No. 29) offences. For a typical mid-sized shop, however, that is not the likely case. Market surveillance is a matter for the federal states, works on a risk basis and rarely starts with a retailer holding five hundred articles. A different route is more realistic: a competitor or an association entitled to sue opens the product page, documents the missing manufacturer detail and issues a warning letter. Breaches of Article 19 are widely classified as a breach of a market conduct rule within the meaning of competition law, and that is exactly what makes them actionable.
That is the honest assessment: the risk arises primarily from warning letters, not from official inspections. In return, that route is fast, cheap to trigger and hits precisely those articles that rank well, because they are found first. The better news is that the remedy stays technically manageable once the data model is in place: four fields, one inheritance rule, one import. The effort lies in obtaining the details, not in displaying them. Anyone working on the shop anyway should take the fields along rather than turn them into a project of their own. How an online shop with clean product data is built so that law, technology and selling fit together is shown on our service page; how to lower cart abandonment in the same pass is described in our article on reducing cart abandonment.