Custom printed apparel and merchandise

• Regulation (EU) 2023/988 — GPSR
• Regulation (EU) No 1007/2011 — textile labelling
• Regulation (EC) No 1907/2006 — REACH
• Directive 2009/48/EC where the item is a children's product with play value

Who has to appoint one

Print-on-demand and merchandise businesses outside the Union selling to EU consumers. Printing on a blank and selling under your own name makes you the manufacturer in law, with the full technical documentation obligation.

Thresholds and exemptions

None. Single-item orders are placing a product on the market in the same way as a production run.

What must appear on the label

Fibre composition, care instructions, size, and manufacturer and responsible person details. The blank supplier's label is not sufficient if you have covered it or if the garment is sold as yours.

Marketplace fields

Marketplaces enforce the responsible person on print-on-demand listings, and this business model was heavily affected when the GPSR fields went live because the sellers had no EU entity.

Documentation you must hold

Technical documentation covering both the blank and the print, the risk analysis, REACH evidence for the inks including phthalates and primary aromatic amines, and the fibre composition documentation from the blank supplier.

Standards and testing

REACH screening on the printed textile, since the ink is part of the finished article, azo dye testing, formaldehyde where finishes are used, and EN 14682 for cords on children's garments.

Language requirements

Fibre composition and care information in the language of each member state of sale, using the official fibre names.

When it applies

Before the listing goes live.

How long records are kept

Ten years.

What happens if you do not comply

Listing suppression, withdrawal and fines. Children's printed garments with plastisol inks have failed on phthalates, which is a finding against the printer rather than the blank supplier.

Who enforces it

Market surveillance and consumer protection authorities and customs.

Where the boundary lies

The print is part of the product: testing the blank does not evidence compliance of the printed article, and phthalates in plastisol inks are a recurring failure. Designs incorporating third-party marks add intellectual property exposure that no compliance file addresses.

Questions we are asked

We just print on certified blanks — is that enough?

No. You place the finished printed article on the market under your name, and the ink is part of it. Your documentation must cover the print.

Do single custom items count?

Yes. Each item supplied to a consumer is a product placed on the market.