EU Product Safety Labelling: What Regulation 2023/988 Asks of Manufacturers and Importers


Articles 9, 10 and 11 in plain words: what goes on the product, and who is responsible when the maker is outside the EU.

Short answer: Regulation (EU) 2023/988 applies from 13 December 2024. Article 9 asks manufacturers to put a type, batch or serial number on the product and to show their name, trade name or trade mark and postal and electronic address. Importers show their own details. If the product is too small, packaging or a document can carry them.

Not legal, customs or tax advice. General information from public pages; confirm with the authority, your customs broker or a lawyer.

What the regulation text says

ProvisionWhat it says
Application dateArticle 52: the Regulation applies from 13 December 2024
Identification, Article 9(5)The product bears a type, batch or serial number or other element enabling its identification; if that is not possible because of size or nature, the information goes on the packaging or in an accompanying document
Contact details, Article 9(6)Manufacturer name, registered trade name or registered trade mark, and postal and electronic address on the product, or if not possible on the packaging or an accompanying document
Importers, Article 11Importers check the manufacturer has met these duties and show their own name, trade name or trade mark, and postal and electronic address on the product, packaging or accompanying document
Authorised representative, Article 10A manufacturer may appoint an authorised representative by written mandate
Who counts as manufacturerRecital 34: a person who places a product on the market under their own name or trade mark is treated as the manufacturer

What the Wikipedia summary adds

  • Non-EU manufacturers need an EU-based economic operator such as an importer, distributor or authorised representative [2]
  • Online sellers display manufacturer, identification and warning information on their offers (the summary cites Article 19) [2]
  • Safety instructions and warnings go in a language consumers understand [2]

Wikipedia is a secondary summary; the regulation on EUR-Lex is the authority [2]. This page does not say which product-specific rules apply to any decor product.

Label planning for an own-brand product

  • [ ] A batch, type or serial element is printed where it can be read [1]
  • [ ] Your brand name and trade mark appear with a postal and an electronic address [1]
  • [ ] If the product is too small, the same data is on the carton or an insert (Article 9 wording) [1]
  • [ ] The importer's details are agreed in the contract and printed [1]
  • [ ] The web listing repeats manufacturer and identification data [2]
  • [ ] Instructions and warnings exist in the language of the sale country [2]

Questions answered

When does Regulation 2023/988 apply?

Article 52 says the Regulation applies from 13 December 2024.

Who is treated as the manufacturer of an own-brand product?

Recital 34 treats a person who places a product on the market under their own name or trade mark as the manufacturer.

Can the details go on the packaging instead of the product?

Yes where that is not possible on the product itself: Article 9 allows the packaging or an accompanying document.

Further reading

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General information, not legal, customs or tax advice. Your written quote and contract govern. Examples use invented numbers unless stated otherwise.