Mandatory information in your listing: what Amazon doesn't check, your competitors will

Since 13 December 2024 the EU General Product Safety Regulation (GPSR) applies. Article 19 requires the distance-selling offer itself to contain four blocks of information: manufacturer contact, for manufacturers without an EU establishment additionally the responsible person in the EU, product identification with an image, and warnings in the language of the target country. Because the regulation's text refers to the content of the offer, the prevailing interpretation is unambiguous — the Händlerbund puts it this way: a link to this information is not sufficient. The data belongs in the offer, not on a page behind it.

• Who is the manufacturer? Under Art. 3 No. 8 GPSR, whoever markets a product under their own name or trademark counts as the manufacturer — regardless of who produced it. That makes practically every private-label seller a manufacturer in the legal sense. “I'm only a retailer” is no retreat then.
• Responsible person in the EU: only needed if the manufacturer has no EU establishment. If your company sits in Germany, you are that person yourself; if you're outside the EU, you must appoint one (Art. 16 GPSR in conjunction with Art. 4 of Regulation 2019/1020).
• Amazon's sanction: in June 2025 Amazon told sellers that an offer with missing or incorrect mandatory information is deactivated within 24 hours of completion. The original notice sits behind the login, public is only the report in a trade medium (as of 4 June 2025); whether the deadline still applies unchanged today is undocumented. So enter the compliance data completely BEFORE you finalize a new offer.
• Where in Seller Central: in the product safety and compliance section of the listing editor (manufacturer contact, responsible person, safety notices) — warnings, CE marks and pictograms additionally as a photo of the packaging in the compliance image slots PS01 to PS06, not in the main image.

Unit price: whoever sells by weight, volume, length or area must state the price per unit of measure under § 4 PAngV (German price indication ordinance) — per 1 kg, 1 l, 1 m, 1 m² or 1 m³; for net quantities up to 250 g or 250 ml also per 100 g or 100 ml. Amazon can only calculate the unit price if net quantity and unit exist as structured attributes. In 2021 Amazon announced it would remove consumable offers without this data from search; whether and in which categories that still happens today is not publicly documented. The unit-price obligation itself doesn't hang on Amazon anyway — it applies regardless of category, and you are liable.

Textile labeling: under Art. 16 of the EU Textile Labelling Regulation (1007/2011), the fiber composition must already be visible in the online offer — before the contract is concluded. The sewn-in label in the delivery isn't enough. You may only state the composition with the names from Annex I, in percent, descending. A brand name like “Lycra” or the US term “Spandex” doesn't replace the official name; at most it may stand right next to it. Fine under § 12 of the German Textile Labelling Act: up to €10,000.

• Packaging (LUCID): since 1 July 2022 a marketplace operator may no longer enable the offering of packaging subject to system participation while the producer isn't registered in the packaging register. Amazon thereby fulfils its own legal duty and blocks accordingly — a support case changes nothing, the offer is unlocked only with the number.
• Electronics (WEEE): for electrical and electronic equipment you need the WEEE registration number under § 6 ElektroG. Registrations apply to one country each: a German number doesn't cover France or Italy — before every new marketplace, check which additional ones are required there. This lesson deliberately names no fine amounts: the circulating figures are not documented.
• Batteries (BattDG): since 18 August 2025 extended information duties apply to batteries and battery-containing devices: information on waste prevention, on separate collection and treatment of used batteries, safety notices and information on the environmental impact of hazardous substances. For distance selling § 24 para. 3 BattDG additionally refers to Article 74 of the EU Battery Regulation — including showing the costs of extended producer responsibility separately to the end user. Under the old Battery Directive exactly that was prohibited.

Efficacy claims on food and supplements: the Health Claims Regulation (1924/2006) reverses the usual logic — only what is explicitly authorized is allowed. Everything else is prohibited, even if true. Claims about curing or alleviating diseases are impermissible; permissible are solely the authorized claims in the approved wording (Community list, Regulation 432/2012). The regulation counts as a market-conduct rule under § 3a UWG: any competitor can send you a cease-and-desist letter directly. That your supplier prints a claim on the packaging is no defense — you are liable for the text in the listing.

Test seals: advertising with test results is only permissible if source and reference of the test are stated in an easily recognizable and findable way. If the reference isn't easily recognizable, courts treat it as if it were missing entirely (including OLG Köln, 10 July 2020). That also applies if you don't advertise the verdict yourself but the seal is merely visible on the pictured product. The seal itself is usually trademark-protected and may only be used under license.

Environmental claims: from 27 September 2026 the rules of the EmpCo Directive (2024/825) apply; the German implementation in the UWG has been adopted. Generic environmental claims such as “eco-friendly”, “climate neutral” or “sustainable” are then only permissible if you can prove recognized excellent environmental performance for the product. Also impermissible: claims based solely on offsetting, self-made seals without independent certification, and future targets without a verifiable, monitored implementation plan. The prohibitions move onto the UWG blacklist and apply without case-by-case balancing.

Three sets of rules interlock for AI images — and none of them requires you to label all AI content across the board:

Rule of thumb: the more photorealistic the image, the more likely it needs labeling — and regardless of any label it must show the delivered product truthfully. Fine range of the AI Act for violations of Art. 50: up to €15 million or 3 percent of worldwide annual turnover, for SMEs the lower amount in each case.

Once per listing, then at every change of product, packaging or copy:

Cease-and-desist letters come from two sides: from competitors (via their lawyers) and from competition and consumer-protection associations. Both work systematically — unit price, textile labeling and environmental vocabulary can be checked across thousands of listings with simple searches; the hits are cheap for the sender, not for you. A study on such letters by the Händlerbund with 164 surveyed sellers isn't representative and relies on self-selection (the publisher sells legal advice) — usable as an order of magnitude, not as trend evidence. What can be said: the topics of this lesson are the classics.

With the 2020 Act to Strengthen Fair Competition, the legislator introduced abuse barriers relevant to you as a seller (evidence grade law; interpretation in the individual case by a lawyer): under § 13 para. 4 UWG, reimbursement of warning costs is excluded for competitors in cases of violations of information and labeling duties in electronic commerce; under § 13a para. 2 UWG, a contractual penalty is excluded for such violations on a first warning if the warned party generally has fewer than 100 employees. These restrictions don't apply to associations. The injunctive claim itself remains in both cases — you must stop the violation.

If a letter arrives anyway:

• Take the deadline seriously: such letters set short deadlines, often one to two weeks. Don't ignore them — otherwise a preliminary injunction follows, which is more expensive.
• Sign nothing unchecked: the enclosed cease-and-desist declaration is often too broad. A lawyer-modified declaration removes the risk of repetition just as well but binds you more narrowly to the actual violation.
• Stop the violation immediately — everywhere: in all listings, all marketplaces, your own shop. A contractual penalty falls due per violation, and associations do check.
• Check the sender: competitors must sell similar goods to a not insignificant extent; serial senders without a real business are challengeable. Your lawyer clarifies that, not you.