The GPSR (General Product Safety Regulation, EU 2023/988) is explicit: all physical products sold to EU consumers must have an identifiable EU-based economic operator who takes legal responsibility for compliance. For manufacturers based outside the EU — including businesses in the United States, United Kingdom, China, Turkey, and every other non-EU country — this means appointing an EU Responsible Person (RP) or ensuring an existing EU importer fulfils this role.
Who is required to have an EU Responsible Person
The RP requirement applies to you if:
- Your manufacturing business is registered outside the EU
- You ship products directly to EU consumers (D2C / dropshipping)
- You sell on EU-facing marketplaces (Amazon EU, bol.com, Cdiscount, etc.) from a non-EU seller account
- You use a fulfilment centre inside the EU (Amazon FBA EU, for example) but your legal entity is outside the EU
If you sell through an EU-based distributor or importer who takes title to the goods, that distributor typically becomes the economic operator responsible for GPSR compliance. Confirm this explicitly in your distribution agreement.
Who can act as your EU Responsible Person
The EU Responsible Person can be:
- Your EU importer — a company within the EU that imports your products, takes title, and resells them. This is the most common arrangement for traditional import/export businesses.
- An appointed EU representative — a third-party service provider established in the EU who holds a written mandate from you to act as RP. These "EU Responsible Person services" have emerged as a business category since GPSR came into force.
- An EU subsidiary or affiliate — if your business group has any EU-registered entity, it can typically act as RP for the group's products sold in the EU.
- A fulfilment centre operator — some EU fulfilment providers are now offering RP services as an add-on. Check your FBA or 3PL agreement carefully — Amazon's fulfilment role does not automatically make Amazon your GPSR Responsible Person.
What the EU Responsible Person must do
Acting as EU RP carries legal obligations:
- Verify that the manufacturer has the required technical documentation and conformity assessments
- Register in the EU Safety Gate / RAPEX system if required for the product category
- Make the technical documentation available to market surveillance authorities on request
- Cooperate with market surveillance authorities in case of incidents or investigations
- Inform the manufacturer and distributors of any safety concerns or regulatory action
- Maintain their name and address on product pages and packaging as the EU contact point
What the EU Responsible Person's details must show on product pages
Your product listings and packaging must display:
- The EU RP's legal entity name (not a trading name alone)
- Their registered address in an EU member state
- An electronic contact (email or contact form URL)
This information must be in addition to the manufacturer's own information — not instead of it. EU consumers need to be able to contact both.
Cost of EU Responsible Person services
Third-party EU Responsible Person service providers have different pricing models:
- Per-product fees: €50–€300 per product line per year, depending on category and complexity
- Annual retainer: €500–€3,000/year for small product ranges (1–10 SKUs)
- Category-specific services: Toys, electronics, and cosmetics have specialist RP providers with specific category expertise
For UK-based businesses post-Brexit: the UK's equivalent UKCA regime has its own "UK Responsible Person" requirement. GPSR EU RP and UK RP are separate — the same provider cannot cover both unless they have entities in both jurisdictions.
What happens if you don't have an EU Responsible Person
Since December 2024, EU market surveillance authorities have been removing non-compliant products from marketplaces and issuing fines. Amazon has started suppressing listings without a valid EU RP on high-risk product categories. German customs has begun intercepting shipments from non-compliant non-EU sellers at the border.
For dropshippers sourcing from China via platforms like AliExpress and selling directly to EU consumers: you — not your supplier — are the economic operator under GPSR if you are the one making the offer to EU consumers. Your Chinese supplier's GPSR compliance status is irrelevant if they are not the party making the sale to EU customers.
Audit your store's GPSR RP compliance
EuroGPSR's automated scanner checks whether your product pages correctly identify an EU economic operator — either a manufacturer inside the EU or an EU Responsible Person for non-EU manufacturers. The scan is free and takes under 2 minutes. Scan your store today to find which product pages are missing the required RP information.