The General Product Safety Regulation (GPSR) states that certain products must come with written warnings and safety instructions. However, it can be challenging to determine when warnings and safety instructions are necessary, and how to write these.
In this guide, we explain when warnings and safety instructions are mandated by the GPSR and the methods you can apply to write suitable instructions for your product.
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Does the GPSR require warnings and safety instructions?
Yes, the General Product Safety Regulation contains provisions that, in certain circumstances, mandate warnings and safety instructions. This is explained below.
(22) Under the general safety requirement laid down in this Regulation, economic operators should be obliged to place only safe products on the market. Such a high level of safety should be primarily achieved through the design and the features of the product, taking into account the intended and foreseeable use and conditions of use of the product. The remaining risks, if any, should be alleviated by means of certain safeguards, such as warnings and instructions.
Article 6 also states that warnings and safety instructions are part of the aspects taken into account when assessing if a product is safe:
(d) the presentation of the product, the labelling, including the labelling regarding age suitability for children, any warnings and instructions for its safe use and disposal, and any other indication or information regarding the product;
The GPSR requires that all products meet a high degree of safety. Yet, warnings and safety instructions can sometimes be necessary to inform consumers of how a certain product should be used to minimise risk further.
Throughout the GPSR, the following types of instructions are mentioned:
1. Warnings (could potentially include written warning texts and warning symbols)
2. Safety instructions
3. Disposal instructions
4. Age suitability
These can be present on the product or the packaging, or included in an accompanying user instruction. Further, The GPSR also states that such information must be present on e-commerce websites.
Which products require warnings and safety instructions?
The General Product Safety Regulation applies to all consumer products sold in the EU, to the extent that a product is not covered by other product-specific regulations. For example, electronics, PPE and toys are already covered by regulations and directives that have existing provisions for warnings and safety instructions.
That said, the GPSR extends these rules to products that were not previously covered by warnings and safety instruction requirements. As such, many companies are currently trying to understand whether such information is necessary for their products, and what they should write.
However, the GPSR does not require that all products come with warnings and safety instructions, as stated in Article 9.
7. Manufacturers shall ensure that their product is accompanied by clear instructions and safety information in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market. That requirement shall not apply where the product can be used safely and as intended by the manufacturer without such instructions and safety information.
As such, warnings and safety instructions are only required when deemed necessary. Whether this is the case often depends on the following two factors:
1. If warnings or safety instructions are part of applicable product standards, or;
2. If the nature of the product requires that it is used in a certain way to minimise its risk
It is therefore unlikely that we will see warnings and safety instructions on t-shirts or flower pots. However, including a maximum weight warning on a baby carrier is likely more reasonable.
How do I know how to write warnings or safety instructions?
The General Product Safety Regulation itself does not contain pre-written warnings or safety instructions. However, there are a few methods you can apply to come up with suitable warnings and safety instructions.
EN standards
The GPSR states that products must comply with certain product standards to fulfil its safety requirements. Certain product standards contain warning texts and symbols that must be followed in order to comply with said standards. This is often the first place to look when trying to identify suitable warnings and safety instructions.
Risk assessment
The GPSR requires that manufacturers create technical documentation, which also contains a risk assessment. In essence, a risk assessment contains potential risks, and measures to mitigate these. Warnings and safety instructions can sometimes be necessary measures to inform consumers of how products are to be used appropriately.
Case study: Blanket with zipper
In late 2024, we were working on a project involving a zippable blanket. We could not identify any standard for this product that contained warnings and safety instructions. Instead, we based the warning texts based on our own risk assessment.
NOT FOR INFANTS OR CHILDREN. DO NOT PLACE IN A BABY COT OR BED.
THIS IS A BLANKET FOR INDOOR HOME USE ONLY. NOT FOR OUTDOOR USE. THIS IS NOT A SLEEPING BAG.
KEEP AWAY FROM OPEN FLAMES.
We requested feedback on these warnings from a national market surveillance authority in the EU. However, they declined to even comment, as they do not provide risk assessments of any sort.
It’s often hard to be absolutely certain that you have identified every single possible risk. In this specific case, we deemed these to be the major risks that could not necessarily be eliminated by complying with safety standards – which is why these warnings were written.
Where should warnings and safety instructions be placed?
The GPSR does not provide an exact placement for warnings and safety instructions. However, several placements are mentioned in the following context:
Article 19: Obligations of economic operators in the case of distance sales
Where economic operators make products available on the market online or through other means of distance sales, the offer of those products shall clearly and visibly indicate at least the following information:
[…]
(d) any warning or safety information to be affixed to the product or to the packaging or included in an accompanying document in accordance with this Regulation or the applicable Union harmonisation legislation in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market.
Our understanding is that warnings and safety instructions can be presented in the following ways:
1. Product and packaging
2. User instructions
3. Websites
Keep in mind that one does not exclude the other. On the contrary, Article 19 states that warnings and safety instructions present on the product, packaging, or user instructions must also be present online. This should not be understood as providing online instructions in lieu of printed instructions is accepted.
What can happen if we do not have warnings or safety instructions?
For starters, not all products require warnings and safety instructions. But, when this is the case, failing to provide this information could result in injuries or investigations that trigger recalls.
Can we use warnings or safety instructions instead of product testing?
No, it is clearly stated in the first section quoted in this article that risks can only be alleviated by the use of warnings and safety instructions. Compliance with applicable product standards is still a requirement.
Hence, products must be physically safe to use, and warnings and safety instructions are merely complements.
Is it sufficient to provide warnings and safety instructions only in English?
Article 9(7) states that products, when necessary, must be accompanied by clear instructions and safety information in a language which can be easily understood by consumers, as determined by the Member State. This is also the case for warnings and safety instructions present online, as stated in article 22.
While many Europeans can read and understand English, it should not be taken for granted that market surveillance authorities in EU member states accept warnings and safety instructions only in English.
I am aware of cases when this has been deemed to be grounds for recalls. It is therefore normally necessary to translate these texts into the national languages of your main markets in the EU.
