must the image on my product page show the safety label

A photo of the label is not required, but its content is

No, the photo on the product page does not need to show the safety label literally in view. What is required: the warnings and safety information that appear on the label must also be visible on the product page itself before purchase — regardless of whether that happens via a photo, a separate text block or a specification table. A photo showing the label can make that information easy to read, but it is not the only way to meet the obligation, and a photo without legible text does not meet the requirement.

Who bears this obligation depends on the role held in the supply chain. Anyone who has products manufactured or imported and sells them under their own name is considered a manufacturer and is responsible for the content of the warnings themselves — and this also applies to the webshop that only puts its own logo on a purchased product, as described on the page about or placing your own brand on a purchased product constitutes manufacturership. An importer bears the obligation to verify that this information is present and correct, but does not draw up the text themselves. A distributor who only resells without their own brand or modification is not required to draw up this information themselves — that obligation then rests with the manufacturer or importer who placed the product on the EU market. Which role applies exactly can be determined via the role check for manufacturer, importer or distributor.

Where that is set out in Article 19 of GPSR

Article 19 of Regulation (EU) 2023/988 governs the information that must be shown to the consumer before purchase in distance sales — including a webshop — including the warnings that appear on the product or packaging. Article 9 sets out which information obligations rest with the manufacturer and Article 11 which rest with the importer, which explains why the source of the text differs by role while the visibility obligation on the page is the same for every seller. What exactly must appear on such a product page is detailed on the page about which information belongs on the product page, and NVWA provides general background on GPSR and product safety.