What obligations does the GPSR impose on you?

In accordance with the new European Union regulation, the General Product Safety Regulation (GPSR), which came into force on 13 December 2024, you must now include new mandatory information in your listings.

What information must be included in your listings

• Manufacturer information:
  • name, registered trade name or registered trademark
  • postal address
  • email address and, optionally, telephone number
• Information about the person responsible for placing the product on the European market – this information is required only if the manufacturer is not established in the European Union:
  • name, registered trade name or registered trademark
  • postal address
  • email address
• Warnings and safety information – for example, information on how to use the product safely:
  • product instructions – add attachments in the official language of the country where the product is sold. This means that, for example, the manual must be available in Slovenian when the product is sold in Slovenia.
  • images of labels on the product packaging
  • text containing product warnings

Where should you add this information?

Manufacturer and responsible-person information must be added to the designated brand/manufacturer fields of your listing.

Warnings and safety information must be provided in the listing through the Manual, XML or API, according to the available fields and requirements.

Frequently asked questions

Who is responsible for the accuracy of the manufacturer information?

As a seller, you are responsible for providing true and accurate information in the required fields.

What happens if I do not bring my listings into compliance with GPSR requirements?

If you do not bring your listings into compliance with GPSR requirements, you may be subject to legal sanctions, including financial penalties.

Who are the manufacturer, distributor and responsible person under the GPSR?

• Manufacturer – means any natural or legal person who manufactures a product or has a product designed or manufactured and markets that product under their name or trademark.
• Distributor – means any natural or legal person in the supply chain, other than the manufacturer or importer, who makes a product available on the market.
• Responsible person – is responsible for ensuring that the product complies with European Union legislation. Under the relevant EU legislation, this may be the manufacturer, authorised representative, importer, distributor, fulfilment service provider or another natural or legal person subject to obligations relating to the manufacture of products, their availability on the market or their putting into service.

Can I list myself as the person responsible for the product in Slovenia?

If the manufacturer or distributor does not indicate another responsible person, you may be able to list yourself. As the responsible person, you will have obligations under EU legislation and will be responsible for ensuring that the product complies with applicable EU requirements.

Who should be listed as the manufacturer if the manufacturing company is my subcontractor in China?

If a product is manufactured by a subcontractor in China and you sell it under your own brand, your company is considered the manufacturer. In this case, you must list your own company as the manufacturer and ensure that the product complies with EU regulations.

The brand whose products I sell uses factories around the world. Do I need to provide information about the country of manufacture?

No. The manufacturer’s address is required. For example, if you sell a Samsung phone, you should provide the address of the manufacturer rather than the address of the factory where the product was manufactured.

What information do I need to provide if I purchase a product from a Slovenian wholesaler, but the product comes from China?

The manufacturer is the Chinese company, while the responsible person in the European Union is the Slovenian wholesaler designated by the manufacturer.

What if I sell a product from China, but purchase it within the European Union and do not have the Chinese manufacturer’s information?

You can request the required information from, for example, the distributor or importer. Since 13 December 2024, manufacturer information must be provided for every relevant listing. If you do not provide it, you may be selling the product in breach of applicable legislation.

I purchase goods from an EU wholesaler and do not know where they come from. How can I find out who the manufacturer is?

You can request the required information from, for example, the distributor or importer. The manufacturer is also required to provide the relevant information on the product.

Do I have to add manufacturer information to all products?

Yes. Since 13 December 2024, the required information must be provided for every new listing offered through Mimovrste. We also recommend updating the required information in all existing listings in categories covered by the regulatory changes.

Can I hide the actual manufacturer and provide my own information instead?

The new legislation provides for financial penalties for providing incorrect information.

What should I do if a distributor markets goods from three factories under one brand?

The manufacturer is relevant, not the individual factory where the product was manufactured.

What does it mean for a product to be placed on the market?

Under the GPSR definition, placing a product on the EU market means making the product available on the EU market for the first time for consumption, distribution or use.

Do I need to include instructions for use with the products?

Under the GPSR requirements, if safety information is required for a product (such as certificates or usage warnings), the seller must make this information available to consumers. If the information is included in the instructions for use, you can provide the instructions accordingly. Safety information must be clear, understandable and available in the language of the country where the product is sold.

Is it sufficient if the manufacturer’s information is stated on the product label?

Manufacturer information must be available to customers before they make a purchase, so it must be visible on the listing page. In the case of distance selling, providing the information only on the product label is not sufficient to meet GPSR requirements.

Must the manufacturer and responsible person’s information be publicly visible?

Yes. Manufacturer and responsible-person information must be publicly visible on the listing page. Consumers must have access to this information before deciding to purchase the product.

Is the EAN the only required parameter for identifying a product?

No. The EAN is one of the product identifiers. Depending on the type of product, sellers must also provide other information, such as the model number or serial number.

As Mimovrste, do you ensure that the responsible-person information I provide complies with GDPR?

We provide sellers with the ability to submit the information required by law and make this information visible to customers in listings. However, we cannot assume the obligations that you, as a seller, have under the new regulation.

As a seller, you are the data controller for the personal data you provide in connection with responsible persons. You are responsible for processing this personal data in accordance with applicable law. When selling through the Mimovrste platform, you entrust us with the processing of this personal data in accordance with applicable regulations. Buyers and sellers on the Mimovrste platform must ensure that the information they provide, including personal data, is current and accurate.