EU GPSR General Product Safety Regulation: 3 Real Boundaries — EU Responsible Person / EU Economic Operator / Traceability Information: Which 3 Fields Should a Printing Factory Put on the Quotation First When Accepting EU Orders

In 2025, a client producing small kitchen appliances sent us a revised design for a set of color boxes. The email read, “The EU side requires the packaging to display the address and contact details of an EU responsible person. Please reserve an area at the bottom of the layout, and we will provide the information for you.”

We reserved the area as requested. After printing, we sent the samples to the client, who replied: “The product has been delisted because the packaging does not contain compliant responsible-person information.”

The client was frustrated: “I clearly printed the address. It is right in the bottom-right corner, in font size 5.”

The root of the problem was not the printing. The client had mistaken the “EU responsible person” for the “EU importer.” These may be two entirely different companies, and the company printed on the packaging does not necessarily have to be the importer. This article explains 3 matters: who should serve as the responsible person, which fields should be printed on the packaging, and how responsibility ends up falling on the printing factory when the responsibility boundaries are not properly defined.

Boundary 1: The EU Responsible Person Is Not the EU Importer

The GPSR (Regulation (EU) 2023/988, General Product Safety Regulation) requires that every product sold in the EU must be traceable to an Economic Operator established in the EU. This operator is responsible for the product’s compliance and must clearly identify itself and provide contact details on the product or its packaging.

The most common confusion arises because several types of operators perform different functions, including manufacturers, EU-authorized representatives, importers, and fulfillment service providers. An “importer” is the company that brings products into the EU market and sells or makes them available in the EU under its own name. The broader term “EU responsible person” covers the entire category of Economic Operators described above.

Consequently, the following combinations are common:

The third arrangement is the one our factory encounters most often. The client is a trading company that clears the goods for import in Europe and then distributes them to sales channels in different countries. For this type of order, the importer’s name, address, and electronic contact details printed on the packaging must all match the customs clearance documents. Customs verifies this information during clearance, and marketplace reviewers verify the same information when approving the listing.

Problems most frequently occur when the client itself has not determined which party should be identified. The client may casually enter the warehouse address of a logistics provider or leave an agency that is no longer working with the company on the artwork.

The printing factory’s approach is straightforward: we print what the client provides, but we point out the error when we discover one. We now require clients to include a verifiable source with the EU responsible-person information, such as an authorization letter, a screenshot of the customs clearance documents, or a link for checking an EU registration number, rather than simply instructing us to print the information as submitted.

Boundary 2: 4 Fields Must Be Printed on the Packaging

Once the responsible entity has been identified, the next question is what should be printed. The packaging must provide enough information to identify the EU Economic Operator, including the following:

• Name—the company’s full legal name, or another name that uniquely identifies the operator.
• Postal address—a physical address where mail can actually be received, not a website or email address.
• Electronic contact details—an email address or telephone number for handling product safety enquiries from consumers.
• Responsible-person identifier—in multilingual or multi-operator scenarios, the packaging must allow recipients to immediately recognize this information as identifying the EU Economic Operator and avoid confusion with the Chinese manufacturer’s address.

Several practical printing considerations apply.

First, these 4 items may appear on any surface of the packaging and do not have to be placed on the front. Clients often request the most prominent front-panel position, but this is a common misconception because the regulation does not impose such a requirement. Printing on the bottom or side may be more practical for retail display. However, we do not recommend omitting a reserved area entirely, because the packaging must contain sufficient information for on-site verification at the retail stage.

Second, technical information supplied electronically, such as a webpage, QR code, or URL, may replace some physical information under specified conditions, but not all of it. The key requirement is that the information must be “conspicuously displayed on the product itself or on the packaging” and must also be accessible electronically. In such cases, some information may be provided online. However, the product’s basic information, including the model, batch, and material identification, along with any warnings, must physically appear on the packaging.

Third, font size matters. The GPSR does not specify a precise minimum height such as 1.8 millimeters for cosmetics PAO symbols, but it does require information to be “clearly legible” and “durably displayed.” Marketplace reviews may apply their own criteria, commonly requiring a size of no less than 3/4 of the smallest font used for other mandatory markings on the packaging. The text should also not be light gray or lack sufficient contrast with the background.

Our factory uses the following approach: we create a separate reserved area for the EU responsible-person information, use a font size that meets or exceeds the customer’s platform minimum, and list it separately on the sample approval sheet for the customer to sign. Once the customer approves the sample, responsibility transfers to the customer. If mass production proceeds without an approved sample, responsibility remains with us.

Boundary 3: What the Packaging Section of the Traceability Documentation Should Contain

The third matter is the technical documentation. This file is usually compiled and retained by the client, but the packaging section is often supplied by the printing factory because the factory holds the physical specifications of the packaging.

The GPSR requires technical documentation to contain information that identifies the product. For packaging, this usually includes the following:

The third row presents the greatest risk. If the printing factory assumes that warnings are not its responsibility, the client may print warnings on the outer shipping carton while leaving the inner gift box blank. Yet the product is ultimately shipped to consumers as an individual retail unit, meaning that the inner gift box is the packaging consumers actually encounter.

Our approach is to ask one specific question during the pre-quotation production discussion: “Are the product warnings and batch number printed on the final unit sold to consumers, or on the outer shipping carton?” Asking this question prevents most later disputes over responsibility.

One more requirement is frequently overlooked: the consistency of manufacturer information. The manufacturer’s name, address, and contact details in the technical documentation must exactly match those printed on the packaging and marked on the product itself. Mixing 2 versions of packaging within the same production batch, or combining an older product with newer packaging, will break traceability.

3 Fields to Include on the Quotation

After considering all these issues, the printing factory’s practical actions can be reduced to 3 requirements. When accepting an EU order, we require the client to confirm the following 3 fields in writing before placing the order. If any field is missing, we notify the client of the risk in writing:

• Role of the EU responsible party—whether it is the importer, authorized representative, fulfillment service provider, or EU subsidiary. This determines whose name is printed.
• Method of information presentation—whether it is physically printed on the packaging or provided electronically through a webpage or QR code. This determines the layout.
• Packaging level for traceability identifiers—whether the batch number and warnings are printed on the sales unit or the transport packaging. This determines how many sets must be printed.

We include these 3 items in the quotation addendum using the following wording:

“The EU compliance layout included in this quotation is produced according to the EU Economic Operator information provided in writing by the client, including the role, name, address, and electronic contact details. The reserved area and font size are specified in the sample approval sheet. After the client approves the sample, the client shall bear all compliance liabilities and losses arising from inaccurate, changed, or untimely updated information. If the client does not confirm the placement of the warnings, the factory will proceed on the basis that the warnings do not appear on this packaging.”

This is not an attempt to shift responsibility. It establishes boundaries that should have been clear from the outset.

Further Reading

• 4 Packaging Compliance Requirements for Exports to the EU: REACH / EC 1935/2004 / 94/62/EC / EN 13427—explains what each additional EU compliance regime covers alongside the GPSR.
• 4 Key Compliance Requirements for UK Exports: UKCA and the UK Packaging Authorized Representative—explains how responsible-party arrangements differ between the UK and the EU after Brexit.
• 3 Compliance Checkpoints for Packaging Exports to the United States: FDA, Prop 65, and CPSIA—provides a comparison with a different market-access framework.
• EU REACH Compliance for Packaging Materials: How to Check the SVHC List—explains that the materials themselves must also comply, in addition to the responsible-party requirements.