Explainer
GPSR: Instructions and Safety Information
The Short Answer
One Sentence in Article 9(7)
The General Product Safety Regulation (GPSR) is short on documentation detail. For instructions it has one core sentence: manufacturers must ensure their product is accompanied by clear instructions and safety information in a language that consumers can easily understand, as determined by the Member State in which the product is made available on the market (Article 9(7)).
The same paragraph carries an exception. The requirement does not apply where the product can be used safely and as intended by the manufacturer without such instructions and safety information. Around those two sentences sit the duties that make the documents matter: a risk analysis, technical documentation, and the requirement that online offers show warnings and safety information.
This page explains the Regulation; it is not legal advice. Read the text and talk to counsel about your products.
Who Must Supply Them
The Operators the Duty Reaches
The duty is not limited to the company that built the product. Four provisions spread it along the supply chain.
- Manufacturers: Article 9(7)
- The product must be accompanied by clear instructions and safety information in a language consumers can easily understand, as determined by the Member State where it is made available on the market.
- Importers: Article 11(4)
- An importer must ensure the imported product is accompanied by the same instructions and safety information, with the same exception.
- Own-brand sellers: Article 13(1)
- Anyone who places a product on the market under their own name or trademark is treated as the manufacturer and carries the manufacturer's duties, including Article 9(7).
- Responsible person: Articles 16(1) and 16(2)
- The economic operator established in the Union who is responsible for the product (Article 16(1)) regularly checks, where appropriate, that the product meets Article 9(5), (6) and (7), and provides documented evidence of those checks to market surveillance authorities on request.
Scope
Which Products Fall Under It
Article 2(1) applies the Regulation to products placed or made available on the market insofar as no specific Union provisions with the same objective regulate their safety. Where a product is subject to specific safety requirements, the GPSR covers only the aspects and risks those requirements leave open. It applies to new, used, repaired and reconditioned products (Article 2(3)).
For products under Union harmonization legislation, Article 2(1) switches off Chapter III, Section 1, which holds Article 9(7), but leaves the online-offer rules in Section 2 in place. In practice a toy, a machine or a medical device takes its instructions rules from its own sector law, and its online listing still has to meet Article 19. Article 2(2) also excludes medicinal products, food, feed, plants and animals, and antiques, among others. For the sector rules see our map of which laws require a user manual.
The Exception
Products That Need No Instructions
The exception in Article 9(7) is conditional: the product must be usable both safely and as the manufacturer intended without instructions and safety information. A simple, low-risk item with an obvious use may pass. A product with a hazard the user would not see, a use that needs setup, or a foreseeable misuse that causes harm will find the test harder.
The Regulation's own safety assessment points the same way. Article 6(1) lists, among the aspects to take into account, the instructions for assembly and, where applicable, installation, use and maintenance (point (a)); the labeling, warnings and instructions for safe use and disposal (point (d)); and the categories of consumers using the product, with attention to vulnerable consumers such as children, older people and persons with disabilities (point (e)).
Writing the warnings is a craft in its own right; our guide to warnings, cautions, and notes covers how to make them clear and findable.
Online Sales
What an Online Listing Must Show
Where operators make products available online or through other means of distance sales, Article 19 requires the offer to clearly and visibly indicate at least the following.
- Who and what
- The manufacturer's name, trade name or trademark, with postal and electronic address; the responsible person if the manufacturer is outside the Union; and information identifying the product, including a picture, its type, and any other product identifier (Article 19(a) to (c)).
- Warnings and safety information
- Any warning or safety information to be affixed to the product or its packaging or included in an accompanying document, in a language consumers can easily understand as determined by the Member State where the product is made available (Article 19(d)).
For a documentation team, point (d) is the practical one: the warning text that goes on the product or in the box has to be available to the writer of the listing too, in the right language. Keeping that text as one maintained source, rather than retyped for each channel, stops the listing and the label from drifting apart. The same discipline is described in single-source publishing.
Format
Digital Copies and Language
The Regulation has no clause that lets a download replace the accompanying instructions. Article 21 allows operators to additionally make the information available digitally, by electronic means clearly visible on the product or, where that is not possible, on its packaging or an accompanying document. That digital information must be in a language consumers can easily understand and available in accessible formats for persons with disabilities. Our comparison of EU rules on digital manuals sets this against rules such as the Machinery Regulation, where digital delivery is allowed with paper owed on request.
The language is set by each Member State, so a product sold in several countries needs the right language for each one. The wording across consumer, machinery and medical rules is compared in instruction language requirements.
Records
The Documents Behind the Instructions
Before placing a product on the market, manufacturers carry out an internal risk analysis and draw up technical documentation, which where appropriate includes the analysis of possible risks and the solutions adopted (Article 9(2)). They keep it up to date and at the disposal of market surveillance authorities for 10 years after the product was placed on the market (Article 9(3)). The warnings in the instructions are the customer-facing end of that risk analysis, so a warning with a recorded basis is easier to stand behind.
The Product Liability Directive adds a second reader. Under Directive (EU) 2024/2853, Article 7(2)(a), the instructions are one circumstance in deciding whether a product is defective, for products placed on the market after 9 December 2026. The two laws overlap on the same pages: the GPSR asks whether the product is accompanied by what it should be, and the Directive asks what a claimant can do when it was not. See the Product Liability Directive and the manual.
FAQ
Questions We Hear
When does the GPSR apply?
Regulation (EU) 2023/988 applies from 13 December 2024 (Article 52). It repealed the General Product Safety Directive 2001/95/EC from that date. Products that met the old Directive and were placed on the market before 13 December 2024 may still be made available (Articles 50 and 51).
Does every consumer product need a printed manual?
No. Article 9(7) does not apply where the product can be used safely and as intended by the manufacturer without instructions and safety information. The text puts the test on safe use as the manufacturer intended, so read it against your own risk analysis. Where any hazard needs a warning or a step the user could get wrong, the exception is hard to rely on.
Can I supply the instructions only as a download or QR code?
Article 9(7) requires the product to be accompanied by the instructions and safety information. Article 21 says operators may additionally make that information available in a digital format, by means clearly visible on the product, its packaging, or an accompanying document. The wording is additive, so the digital copy does not replace what accompanies the product. Read both articles for your case.
Which language do the instructions need to be in?
A language consumers can easily understand, as determined by the Member State where the product is made available (Article 9(7)). The Regulation does not name a language itself, so the answer is set country by country. Our guide to instruction language requirements compares the rule across several EU regulations.
Does the GPSR apply to a product that has its own EU safety law?
Only in part. Article 2(1) applies the Regulation to aspects and risks not covered by the specific rules. For products under Union harmonization legislation, Chapter II (insofar as the harmonized rules cover the risks) and Chapter III, Section 1 (including Article 9(7)) do not apply, while the online-offer rules in Chapter III, Section 2 (Article 19) do. Toys, machinery and medical devices have their own instructions rules. Check Article 2 and the sector rule for your product.
How does the GPSR connect to the new Product Liability Directive?
They are separate laws with different jobs. The GPSR sets safety duties and is enforced by authorities. The Product Liability Directive gives injured people a route to compensation, and it counts a product as defective if it lacks the safety required under Union or national law (Directive (EU) 2024/2853, Article 7(1)). Instructions appear in both: as an aspect of safety under GPSR Article 6(1) and as a defect factor under Article 7(2)(a) of the Directive.
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