must my product packaging comply with GPSR rules in addition to the label

Packaging has its own obligations, separate from the label

Yes, the packaging is subject to the same obligations as the product and the label itself, and this is a distinct point of attention in addition to the text on the label. Article 9 of Regulation (EU) 2023/988 explicitly names the packaging as a place where identification data and warnings may appear — not as free space for marketing only, but as a carrier of mandatory information. Anyone treating this as a minor matter misses part of what actually needs to happen.

This primarily concerns the manufacturer. And that is precisely where many entrepreneurs are mistaken: anyone who sells a product under their own name or brand is themselves considered a manufacturer under GPSR, even if the packaging and product are already purchased ready-made from a supplier elsewhere. Simply affixing your own logo to existing packaging changes nothing — the obligation to ensure the packaging is correct then lies with that party itself. Am I a manufacturer if I put my own brand on a purchased product? goes into greater detail on when that is the case. A distributor — anyone who merely resells a product without presenting it as their own brand — does not bear this obligation themselves; that role primarily involves checking that the packaging and label are already present, not that they are created by them.

Why Article 9 mentions packaging alongside the product

Article 9 of Regulation (EU) 2023/988 describes the obligations of manufacturers and states that the name, registered trade name or brand and contact details must appear on the product, the packaging, the package or an attached document — the packaging is therefore one of the possible, and in practice often necessary, places where this is checked. The same article also governs product identification via type, batch or serial number, for which must I apply a batch number to my products? further explains where that number belongs. For anyone importing products from outside the EU, Article 11 provides a comparable point of attention: it is checked whether the packaging already bears the correct information before the product enters the EU market.