EU product marking · GPSR (EU) 2023/988 + NLF 768/2008/EC
Which traceability marks must you place?
Every product (or its packaging, or an accompanying document where size or nature does not allow on-product marking) must carry a type/batch/serial identifier plus the manufacturer's name + trade mark + postal contact address — and the importer must add its own. Pick your role and regime to get the exact set.
The rule, in one line
Under GPSR (Regulation (EU) 2023/988, Arts 9 & 11, applies from 13 December 2024) for general consumer products, and under the New Legislative Framework reference provisions (Decision 768/2008/EC, as enacted in the sector directives) for CE-marked harmonised products, the manufacturer places a type/batch/serial identifier plus its name, registered trade name or trade mark and a postal contact address; the importer additionally places its own name and contact address. Where size or nature does not allow on-product marking, the information goes on the packaging or in an accompanying document. Place a product on the market under your own name or trade mark — or substantially modify it — and you are treated as the manufacturer.
Official sources: GPSR (EU) 2023/988 · EC — New Legislative Framework · EC — CE marking (manufacturers)
Traceability label verdict
Manufacturer label set
You place a type/batch/serial identifier plus your name, registered trade name/trade mark and a postal contact address. Where size or nature prevents on-product marking, the information goes on the packaging or in an accompanying document.
What you must place / check
- Place a type, batch or serial number (or other identifying element) on the product.
- Place your name, registered trade name or trade mark and a postal contact address (a single contact point) on the product.
- Make a complaint communication channel available (telephone number, electronic address or website section), accounting for accessibility (GPSR Art 9).
Legal basis for your case: GPSR (Reg (EU) 2023/988), Arts 9 & 11 — general consumer products.
Per-product memo
Traceability label memo (PDF) · €29
A print-ready pack for one product: the role-specific label-element checklist, the placement wording, the legal basis (GPSR vs NLF) with article citations, and source links — for your technical file.
This is guidance, not legal advice. The export restates the generic label set for your inputs; it does not enumerate the extra marks your specific sector directive may require.
What this tool is — and isn't
This checker routes the traceability label-element question by role under GPSR (Reg (EU) 2023/988, Arts 9 & 11) and the NLF reference provisions (Decision 768/2008/EC), using EUR-Lex + the European Commission's single-market pages. It gives the GENERIC checklist common to both and tells you which legal basis applies — it does not claim to give the complete labelling set for a specific CE-marked product (each sector directive has its own article numbers and may add marks, and separate regimes such as energy, chemical/CLP, age or warning marks are out of scope). It is an estimate and orientation, not legal advice. Verify against the linked official sources and your sector directive.
How the determination works
1. Are you the manufacturer (or treated as one)?
Placing the product on the market under your own name or trade mark — or substantially modifying it — makes you carry the manufacturer's identification + identifying-element duties, whatever your stated role.
2. Your role decides which marks are yours
Manufacturers place the identifying element + identity; importers add their own identity and verify the manufacturer's marks; distributors verify only and must not supply if marks are missing.
3. The regime decides the legal basis
General consumer products follow GPSR Arts 9 & 11 (with a complaint communication channel); CE-marked harmonised products follow the NLF reference provisions plus CE marking + a declaration of conformity. Where there's no space on the product, every mark moves to the packaging or an accompanying document.
Frequently asked questions
- What exactly is a 'traceability label element'?
- The marks that let an authority identify a product and trace it through the supply chain: a type, batch or serial number (or other identifying element), plus the manufacturer's name, registered trade name or trade mark and a postal contact address — and the importer's own name and address.
- What if there is no room on the product?
- Where the product's size or nature does not allow it, the information is placed on the packaging or in a document accompanying the product. The tool toggles every 'on the product' line to that fallback when you say there's no space.
- I import and sell under my own brand — what am I?
- You are treated as the manufacturer. Placing a product on the market under your own name or trade mark (or substantially modifying it) means you carry the full manufacturer identification + identifying-element duties.
- Does GPSR or a sector directive apply to my product?
- CE-marked harmonised products (EMC, LVD, Machinery, Toys, RED, PPE…) follow their sector directive's reference provisions; other consumer products follow GPSR. The element set is largely common, but the sector directive may add marks — confirm which regime applies.
- What is the complaint communication channel?
- GPSR Art 9 requires manufacturers to make a channel available (telephone number, electronic address or website section) for consumers to submit complaints or report accidents, accounting for accessibility. Importers verify it exists and provide one if not. The NLF reference provisions do not impose this.
- Is this legal advice?
- No. This tool routes the generic traceability label set by role and tells you the legal basis. It is orientation, not legal advice, and does not enumerate the extra marks a specific sector directive may require. Verify against the linked official sources.