Saya & Associates
EU product listings: what a marketplace must check before publishing
A detailed seller agreement and a thin listing form
An EU-facing marketplace may have a detailed seller agreement and a simple listing form. The agreement requires accurate product information, but the form asks only for a title, price, description and image.
The product goes live. The information a customer or authority needs stays in a supplier's inbox. At that point a contractual obligation has become a product-design question.
The GPSR places duties on economic operators selling at a distance and, separately, on providers of online marketplaces. Product-specific rules may add more.
A seller warranty is no substitute for a listing interface that captures and displays the required information.
What the EU's 2026 sweep found
Between May and July 2026, national authorities screened nearly 1,700 offers of childcare and sports products on 35 online marketplaces. The European Commission published the results on 7 September 2026.
| Finding | Result |
|---|---|
| Marketplaces registered on the Safety Gate Portal with a contact point for authorities | 91%, up from 53% the year before |
| Marketplaces with a single contact point for consumers | 100%, up from 64% |
| Offers showing manufacturer details, the EU responsible person and product identification together | 58% |
| Orders sent to marketplaces over non-compliant listings | 560 |
The figures describe the offers sampled, not every EU listing. The lesson is that company-level and listing-level compliance can diverge. A platform can register its contact point and still publish offers with missing fields.
What must an online offer show?
Article 19 of the GPSR requires an offer made online or at a distance to indicate clearly and visibly at least:
- the manufacturer's name, registered trade name or registered trade mark, with a postal and an electronic address;
- where the manufacturer is not established in the EU, the name, postal and electronic address of the EU responsible person;
- information identifying the product, including a picture, its type and any other product identifier; and
- any warning or safety information required on the product, its packaging or accompanying documents, in a language consumers can easily understand.
Sector-specific EU legislation may require more for particular products.
What the marketplace must do
Article 22 sets separate duties for providers of online marketplaces:
| Duty | Article 22 |
|---|---|
| Designate a contact point for market surveillance authorities and register on the Safety Gate Portal | Paragraph 1 |
| Designate a contact point for consumers on product safety | Paragraph 2 |
| Have internal processes for product safety | Paragraph 3 |
| Act on an authority's order about a dangerous product within two working days | Paragraph 4 |
| Process product-safety notices within three working days | Paragraph 8 |
| Design the interface so traders can provide the Article 19 information and it is displayed or easily accessible on the listing | Paragraph 9 |
The distinction matters. The seller may owe the duty to supply correct data. The platform still controls the fields, validation rules and publication workflow through which that data reaches the consumer.
Audit the journey of one product record
Choose one product actually offered to EU customers and trace it through six steps:
- Check the source. Find who supplied the manufacturer, responsible-person and identification details, and whether a current product record supports them.
- Test the entry form. Confirm the seller can enter each required field for the category and destination, and that a blank or placeholder value cannot pass.
- Test the approval step. Establish who checks the information before publication, and what happens when it is incomplete or inconsistent.
- Check the live listing. Confirm the consumer-facing offer shows the information clearly; a complete back-office record is not a complete listing.
- Test a change. Establish who updates live offers when a manufacturer, responsible person, warning or product identifier changes.
- Rehearse an authority order. Check the team can act on an order within two working days and process a safety notice within three.
This is a practical test, not a rule that every field needs manual approval. The right control depends on volume, category, risk and the platform's role.
What the seller agreement can and cannot do
The agreement can allocate who supplies information, who confirms it, when changes must be notified, what records the marketplace may request and when an offer can be paused.
But if the onboarding form does not capture the information, or the publish control ignores missing data, stronger wording will not fix the live offer.
Start with a joint review by product, operations and legal of one real listing and its record. Decide who owns each field, what evidence supports it and when publication is blocked. Then finalise the contract around that workflow.
Trader identity checks under the Digital Services Act are a separate gate. See EU marketplace seller onboarding under the DSA.
Frequently asked questions
What must an EU online product listing show under the GPSR?
Article 19 requires the manufacturer's name and contact details, the EU responsible person where the manufacturer is outside the EU, product identification including a picture and type, and any required warnings or safety information.
Does the GPSR apply to marketplaces or only to sellers?
Both, in different ways. Sellers must show the Article 19 information.
Under Article 22, marketplace providers must let traders provide it, display it on the listing, register on the Safety Gate Portal and keep internal product-safety processes.
How quickly must a marketplace act on an authority's order?
Without undue delay, and in any event within two working days of receiving an order about a dangerous product, under Article 22(4). Product-safety notices must be processed within three working days under Article 22(8).
When did the GPSR start to apply?
On 13 December 2024. It applies to consumer products placed or made available on the EU market, including those sold online.
Does an Indian seller's listing need an EU responsible person?
Where the manufacturer is not established in the EU, Article 19 requires the listing to name the EU responsible person, with postal and electronic addresses. Who that person is depends on the supply chain.
The takeaway
Listing compliance is decided by the form, the validation rules and the publish button, not by the seller agreement alone. Audit one real product record end to end before scaling EU sales.
To discuss a specific marketplace, contact Saya & Associates.
This article provides general information as at 28 September 2026. Obligations depend on the product, the parties' roles, the destination market and other EU or national rules. It is not legal advice.