The EU Responsible Person (RP) is a requirement introduced by GPSR for any product sold in the EU that is manufactured outside the EU. If you are a brand based in the US, UK, China, Australia, or any other non-EU country, and you sell physical products to EU consumers, you need an EU Responsible Person.
What is an EU Responsible Person?
An EU Responsible Person is a legal entity (company or individual) located within the European Union that accepts specific legal obligations regarding your products on your behalf. They serve as the point of contact for EU market surveillance authorities.
Under GPSR Article 16, the EU Responsible Person must:
- Keep the Declaration of Conformity and technical documentation accessible
- Provide competent authorities with all information necessary to demonstrate product safety
- Cooperate with authorities on any corrective action, including product recalls
- Register complaints and non-conforming products in the manufacturer's register
Crucially, the EU Responsible Person's name and EU address must appear on the product (or its packaging) AND in online product listings. It is not sufficient to have an RP who is not disclosed to consumers.
Who needs an EU Responsible Person?
You need an EU Responsible Person if:
- You manufacture products outside the EU, and
- Those products are sold to consumers in EU member states
You do NOT need a separate EU RP if you are an EU-based importer, because the importer itself fulfils the RP role under GPSR Article 13. Similarly, an EU-based authorised representative acting on behalf of a non-EU manufacturer fulfils the RP obligation.
How to appoint an EU Responsible Person
The appointment must be in writing — typically a signed agreement that explicitly grants the RP authority to act on your behalf and defines the scope of products covered. The agreement should specify:
- The full legal name and registered EU address of the RP
- The specific product categories or SKUs they cover
- Their obligations (maintain documentation, cooperate with authorities)
- Duration of the appointment and termination conditions
Once appointed, the RP's details must be added to your product packaging/labels and to all online product listings.
EU Responsible Person service providers
A growing industry of RP service providers has emerged to serve non-EU brands. When evaluating providers, consider:
- EU registration. Verify the RP is actually registered in an EU member state (not just claiming an EU address).
- Product category expertise. Some providers specialise in specific categories (electronics, toys, cosmetics). Category expertise matters for technical documentation requirements.
- Turnaround time. How quickly can they issue appointment documentation? Some enforcement actions move fast.
- Cost structure. Annual fees typically range from €50 for a single product category to several hundred euros for multi-category coverage. Be wary of very low-cost providers who may lack genuine legal capacity to fulfil RP obligations.
What happens without an EU Responsible Person?
Selling products in the EU without a properly appointed and disclosed EU Responsible Person is a GPSR violation. Consequences include:
- Market surveillance authorities can order products withdrawn from the EU market
- Marketplace platforms (Amazon, Zalando) can suppress listings that lack RP information
- Fines vary by member state: up to €100,000 in Germany, up to €900,000 in the Netherlands, up to €5,000,000 in Italy
The EU Responsible Person requirement has been one of the most operationally challenging aspects of GPSR for non-EU brands. But with the right provider and a clear appointment agreement, it can be resolved in a few days.