GPSR product identifiers: batch, serial and type numbers on Shopify

The General Product Safety Regulation, Regulation (EU) 2023/988, asks for a product to be identifiable in two places: on the product itself and in your online offer. Many stores mix up the two duties, or leave the identifier out of the listing entirely. This guide explains which identifier goes where, why it matters when something goes wrong, and how to handle it in a Shopify store selling to EU customers.

The other Article 19 details (manufacturer, EU responsible person, warnings) are covered in GPSR on Shopify. For the regulation as a whole, start with the GPSR explained for Shopify stores.

1. On the product: Article 9(5)

Manufacturers must make sure their products bear a type, batch or serial number or other elementthat enables the product to be identified and is easily visible and legible for consumers (Article 9(5)). Where the size or nature of the product does not allow it, the information goes on the packaging or in a document accompanying the product. The next paragraph, Article 9(6), adds the manufacturer's name and postal and electronic address, under the same fallback rule.

The check runs down the supply chain. An importer makes sure, before placing a product on the market, that the manufacturer has met Article 9(5) (Article 11(1)). Where it considers or has reason to believe that the product falls short, it may not place it on the market until the product has been brought into conformity (Article 11(2)). A distributor verifies the same point before making the product available (Article 12(1)). Where a distributor has reason to believe, on the information it holds, that a product does not meet Article 9(5), (6) and (7) or Article 11(3) and (4), as applicable, it may not make the product available until it has been brought into conformity (Article 12(3)).

So if you resell other brands, putting the identifier on the product is not your job, but checking that it is there is. If you make the product yourself, or have it designed or made and sell it under your own name or trademark, the GPSR treats you as the manufacturer (Article 3(8), Article 13(1)), and making sure the identifier is on the product is your duty. That will usually include private-label stores and print-on-demand stores that sell under their own brand.

2. In the listing: Article 19(c)

Where you sell online, the offer must clearly and visibly show, among other things, “information allowing the identification of the product, including a picture of it, its type and any other product identifier” (Article 19(c)). In practice this means the model on offer, not the individual unit that ends up in the parcel. The point is that customers and market surveillance authorities can match the listing to the product in their hands, for example during a recall.

Article 19 does not say which identifier to use, and we have not found Commission guidance that settles it. In practice the safe set is a picture of the variant on sale, a clear product name that says what it is, and an identifier that also appears on the product: usually the type or model number, or the GTIN printed on the packaging.

3. Which identifier goes where

4. Why batch numbers matter in a recall

The batch or serial number rarely belongs in the listing, but it becomes central the moment something goes wrong. A written recall notice must describe the recalled product clearly, including “product identification numbers, such as batch or serial number” and, if applicable, a graphic showing where to find them on the product (Article 36(2)(b)). If only one batch is affected, the batch number is what tells a customer whether their lamp is part of the recall.

Recalls also reach customers directly. Economic operators must make sure all affected consumers who can be identified are notified directly and without undue delay, and those that collect their customers' personal data must use it for recalls and safety warnings (Article 35(1)). A Shopify store holds that data in its orders. Whether you can narrow a recall to the right orders depends on whether you can link batches to orders. The same applies to accident reports: a manufacturer's notification through the Safety Business Gateway includes the type and identification number of the product (Article 20(1)). How withdrawals and recalls run in practice is covered in GPSR enforcement and recalls.

5. Product identifiers on Shopify

Shopify has no GPSR-specific identifier field. The standard product and variant fields cover most of what Article 19(c) asks for:

• Product and variant titlesfor the type of product, such as “Table lamp Lumo”, and for options like colour or size.
• A product metafield “Model” for the type or model number. Themes that support dynamic sources can show it on the product page from the theme editor; older themes may need a small Liquid edit or an app.
• The variant Barcode field for the GTIN, EAN or UPC. Many themes do not show it by default, so check your live product page and add it where needed. If variants differ in model number, a variant metafield keeps each value with its variant.
• The SKU only if the same code appears on the product or its packaging. Otherwise it stays an internal number and does not identify the product for the customer.
• Variant images, so the picture matches the variant the customer selects.
• The product descriptionas a fallback: a line such as “Model: LM-30 · GTIN: 4006381333931” is plain but visible. The Disclosures field is meant for warnings, so keep identifiers out of it.

Batch-level tracking.Shopify's standard inventory counts stock per variant and location. It does not, as standard, record which batch or serial number went into which order. If your products carry batches that could be recalled separately, record them outside the listing: in your warehouse or fulfilment provider's system if it tracks lots, in an inventory app, or at least in a goods-in log with dates that you can match against order dates. Check what your own fulfilment set-up supports before you rely on it.

The Complimus GPSR module shows a translated product safety block with the manufacturer, the EU responsible person and links to documents on the product page. It does not add batch numbers or product identifiers, so keep those in Shopify's own fields as described above. If the manufacturer is outside the EU, see the EU responsible person for Shopify stores.

6. Common mistakes

• The product carries no identifier, and the store sells it anyway.
• The listing shows only an internal SKU that customers cannot find on the product.
• The photo shows a different variant or a previous model.
• The model number sits only in a downloadable PDF, not in the listing itself.
• Batch numbers are never recorded, so a recall may have to go to every buyer of the product.

7. Checklist

• Does every product carry a type, batch or serial number or another legible identifier, on the product or, where that is not possible, on the packaging or an accompanying document?
• Does every listing name the product type and show an identifier that also appears on the product?
• Does every variant have a matching photo?
• Is the model number or GTIN visible on the live product page, not only in the Shopify admin?
• For a recall, can you link batches or serial numbers to orders?

Frequently asked questions

Sources

• Regulation (EU) 2023/988 on general product safety (GPSR)