Can You Place GPSR Labels on Packaging Instead of the Product?

Toys and Children’s Products

Toy safety rules are strict in both the EU and UK. The EU Toy Safety Directive (2009/48/EC) and the UK equivalent require toys to show the CE or UKCA mark, the manufacturer’s name and address, and a model or batch number. Like the GPSR, the rules say this information must be on the toy itself, unless the toy’s size or nature makes that impossible, in which case it can go on the packaging or in a leaflet.

In practice, many toys carry labels both on the product and on the packaging. A teddy bear, for example, might have a sewn-in tag with the maker’s details and a batch code, while the box repeats this and adds warnings such as “Not suitable for children under 3 years.” For very small items, like marbles, the packaging alone carries the full details because the toys themselves cannot be marked.

Regulators stress that manufacturers cannot avoid marking a toy just because it affects appearance or adds cost. If a small imprint is technically possible, as with a rubber ball, it is expected. The fuller details can then go on the packaging. The basic rule is clear: toys should be labelled directly whenever possible, with packaging used only when necessary.

Packaging also has a special role for safety warnings. Legal requirements mean warnings about choking hazards, age limits, or safe use must be visible at the point of sale. This usually means printing them on the box or tag, not hiding them inside a leaflet. In other words, packaging often carries the main warnings, while the toy itself should carry at least the essential identification.

Electronics and Electrical Goods

Electronics and electrical goods are covered by their own safety laws, such as the UK’s Low Voltage Electrical Equipment (Safety) Regulations 2016 and, in the EU, the Low Voltage, EMC, and Radio Equipment Directives. These rules require the manufacturer’s name and address, plus a model or type number, to appear on the product itself whenever possible. If not, the information can go on the packaging or in the manual. UK guidance makes this explicit: the details must be on the equipment, or if that’s not possible, on its box or documents. The information also has to be clear, legible, and in the local language (English in Great Britain).

In practice, most electronics are big enough to carry this information directly. A laptop or smartphone will usually have a plate, label, or laser etching with the brand, model, and regulatory marks. For smaller devices, like earbuds or smartwatch sensors, there may be no room. In those cases, the box or instruction leaflet carries the full details. The EU’s Radio Equipment Directive even allows certain markings in the manual if the device itself is too small.

Electronics also need safety and environmental symbols, such as the crossed-out bin for WEEE disposal or voltage warnings. These must go on the product if there’s space, but may appear on the packaging if not. Importer details add another layer: CE-marked products sold in the EU must show an EU contact, and UKCA products need a UK contact. In the UK, until the end of 2027, importer details can appear on the packaging instead of the product. This is why many boxes now show dual addresses for the EU and UK.

In short, most electronics carry at least some information directly on the device, while fuller details often appear on the packaging. This is acceptable as long as it follows the specific product rules and the GPSR’s principle: use packaging only when the product itself can’t reasonably be marked.

Cosmetics and Personal Care Products

Cosmetics have some of the strictest labelling rules, set by the EU Cosmetics Regulation (EC) No 1223/2009 and mirrored in the UK. Every cosmetic product must show specific information on its container and/or its packaging. This includes the name and address of the “Responsible Person” (usually the manufacturer or importer), the net quantity, expiry date or period-after-opening symbol, batch number, product function (if not obvious), warnings, and a full list of ingredients.

Because many cosmetic containers are small, the law allows flexibility. If all the information can’t fit on the container, it can appear on the outer box or on a leaflet inside, with a symbol on the packaging pointing consumers to that extra information. For example, a mascara tube might only have a batch code and a PAO (open jar) icon, while the retail box provides the manufacturer’s details, ingredient list, and safety warnings.

In practice, cosmetics usually carry minimal information directly on the jar, bottle, or tube (such as the batch number and PAO), while the outer packaging carries the full label. This differs slightly from general GPSR products, because cosmetic packaging is the primary carrier of required details. The GPSR still applies for general product safety, but in terms of labelling, compliance with the Cosmetics Regulation takes priority.

Manufacturers selling a cosmetic without outer packaging must place all the required information directly on the product (or on an attached tag). If space is too limited for certain details, a leaflet or card must be included and clearly indicated. The rules also require that labelling be in the local language (except for ingredients, which use international naming standards).

In essence, cosmetic packaging is the main place for safety and identification information, while the product container carries as much as possible. This approach fits with the GPSR principle that GPSR labels can be placed on packaging when the product’s size or nature makes full on-product labelling impractical.

Household Goods and Other Consumer Products

Household goods cover a wide range of products – from kitchenware and furniture to DIY tools and cleaning products. Many of these items have no specific EU-wide regulation and so fall under the GPSR alone, while others, like detergents or paints, are covered by separate rules such as the CLP Regulation for chemicals.

For general household items like cookware, dishes, or furniture, the GPSR requires that the producer’s name and address, plus a product identifier, be provided. Often this information appears on the packaging or a hang tag, especially where the product itself isn’t suitable for a permanent label. A frying pan, for example, might come with a cardboard sleeve listing the manufacturer’s details, while the pan itself only carries a logo. This approach is generally acceptable since consumers would not expect a full postal address etched onto metal or glass. Still, best practice is to put at least a brand name or logo on the product, with fuller details on the packaging.

For appliances, the electronics rules apply, and for furniture and textiles there may be extra national requirements, such as fire safety or fibre content labels. Where those don’t apply, the GPSR traceability rules still do. Some furniture comes with a small plate or sticker underneath, but if that isn’t practical, packaging or an instruction sheet can carry the necessary information. The principle remains the same: label the product if reasonable, otherwise use packaging or documents.

Household chemicals are handled differently. Under the CLP Regulation, containers themselves must carry hazard labels, so a bleach bottle must always display warnings directly on it. In this case, the “packaging is the product,” and those specific labelling rules take precedence. The GPSR acts as a safety net, covering risks not addressed by sector-specific laws, such as the mechanical safety of a child-resistant cap.

Simply put, for household goods the general rule is straightforward: label the product if you can, and if not, rely on packaging or an insert. Products normally sold in packaging should carry the required information there. If something is sold loose, like a single hardware tool, a hang tag or slip with the manufacturer’s details should accompany it.