This regulation requires that manufacturers have a duty of care to provide safe products to the consumer, undertaking the necessary risk assessments evaluating the safety of the product, providing sufficient usage instructions and applicable warnings, ensuring product traceability and providing contact details on the product should the consumer have any questions on the use and safety of the product.
Of interest, includes cosmetic products, which are already regulated by EU Cosmetic Product Regulation (CPR) with a cosmetic product safety assessment carried out, which supports the safety aspects of the newly revised GPSR.
The purpose of the newly revised regulation is to address the increased number of products on sale online, which should also include safety and warnings of use online together with details of the manufacturer, importer or distributor in EU, where consumers can contact.
For all other non-cosmetic products, manufacturers must have a robust process in place, where the safety of the product is evaluated, before it is placed on the market for sale.
Impact to Product Labelling Requirements
(a) The name registered trade name or trademark of the manufacturer, as well as the postal and electronic address at which they can be contacted;
(b) Regarding the manufacturer: for cosmetic products, the manufacturer is understood as the “Responsible Person”, or the person nominated for placing the product on the market. This can be brand owner.
(c) Postal address: for cosmetic products and in line with the CPR, Art. 19.1.a, the postal address can be abbreviated to identify the ‘responsible person’ and their address. For consistency, the abbreviation option allowed by the CPR should also apply to the information required under the GPSR, Art. 19.1(a).10
(d) Electronic address: this is understood as either an email address or a company website address.
(e) In the case where the manufacturer is not established in the EU, the name, postal and electronic address of the Responsible Person shall be indicated, as noted above.
(f) Note: Responsible Person: the CPR requires that for imported cosmetic products into EU, each importer shall be the ‘responsible person’ for the specific products that he/she places on the EU market; with applicable postal and electronic address as indicated above.
