must I state from what age a product is safe

Age guidance is part of safety information, not separate from it

Age guidance is not listed as a separate mandatory element in the GPSR, but falls under the broader obligation to inform the consumer about risks associated with normal or reasonably foreseeable use of a product. Where an age limit is relevant to the safety of a product — such as toys, child care articles or products with small parts — that information belongs in the safety information that the manufacturer provides with the product. Whether age guidance is necessary in a specific case follows from the risk analysis of that product; that is not a question this platform answers, but one that is recorded in the product dossier.

Who mentions this varies depending on the role in the supply chain. The manufacturer determines on the basis of the risk assessment which warnings and use restrictions — including any age guidance — belong with a product, and ensures that information is included in the instructions and on the packaging. The importer verifies that this information is present and correct, but does not determine it themselves. A distributor who resells products unchanged does not need to determine age guidance themselves — that role only verifies that the manufacturer or importer has already provided the required information. Anyone who modifies the product or packaging themselves, or sells it under their own name or brand, falls under the manufacturer obligations and bears the responsibility for that content themselves — even if the product was purchased from another party and only their own logo was placed on it. The fact that age guidance is present is then not enough: it must also be substantiated by the risk analysis of that specific product.

Where this follows from: Article 9 and Article 19

Article 9 of Regulation (EU) 2023/988 requires the manufacturer to assess risks and inform the consumer about safety risks that may result from use of the product — an age limit is a possible outcome, not a standalone requirement. Article 19 governs which information must be visible before purchase in distance sales, which is relevant for which information must appear on the product page under the GPSR. Article 11 places an obligation on the importer to verify that the manufacturer has provided this information, without the importer determining the content themselves. For those uncertain about their own role in that supply chain, which role you hold under the GPSR clarifies that further.