EU Responsible Person Under GPSR
GPSR 2023/988 requires every product sold to EU consumers to have an identified EU Responsible Person. This guide explains who qualifies, what they must do, and how to appoint one.
GPSR Article 4
What is an EU Responsible Person?
GPSR Article 4 establishes a chain of responsibility. For any product placed on the EU market, at least one economic operator within the EU must be identifiable as responsible for product safety compliance. This is the EU Responsible Person.
The regulation specifies who can fill this role in order of priority:
1
The manufacturer, if established in the EU
They are automatically the EU Responsible Person.
2
The importer
If they import products from a non-EU manufacturer into the EU market.
3
An authorised representative
A legal entity in the EU appointed by the manufacturer via a written mandate.
4
The fulfillment service provider
In specific circumstances where no other economic operator is identifiable.
Scope
Who must appoint an EU Responsible Person?
If you are a manufacturer based outside the EU (UK, USA, China, Turkey, etc.) selling products directly to EU consumers — including via your own ecommerce store, Amazon.de, or any other channel — you must have an EU Responsible Person before your products can legally be sold in the EU.
UK sellers: Since Brexit, UK-based sellers are treated as non-EU manufacturers and must appoint an EU Responsible Person to sell into EU member states.
Exceptions that do NOT require a separate appointment:
You already have a registered legal entity in an EU member state (that entity IS your EU Responsible Person).
You sell only to EU-based importers or distributors who take title to the goods (they become the EU Responsible Person).
Your products are purely digital (GPSR applies only to physical products).
GPSR Article 4(3)
What an EU Responsible Person must do
The EU Responsible Person has concrete legal obligations under GPSR Article 4(3). These are not administrative formalities — they carry real legal liability.
Verify that the manufacturer has drawn up the required technical documentation and safety assessment.
Register the product in the EU Safety Gate portal if required by applicable legislation.
Maintain a copy of the declaration of conformity for 10 years.
Cooperate with market surveillance authorities and take corrective action on unsafe products.
Inform the manufacturer and market surveillance authorities when a product poses a risk.
Include their name, trademark or brand, and postal address on the product or packaging.
Appointment process
How to appoint an EU Responsible Person
Appointment is done via a written mandate (contract). The mandate should specify:
The products covered (by name, model, category, or all products).
The geographic scope (EU market).
The specific obligations the representative accepts.
Duration and termination provisions.
Liability allocation between manufacturer and representative.
Typical cost: Services that provide EU Responsible Person appointments typically charge €200–€2,000 per year depending on product categories and risk level.
GPSR Article 9(1)
What must appear on the product, packaging, or listing
GPSR Article 9(1) requires the EU Responsible Person's details to appear on or with the product. For ecommerce stores, this information must also be accessible on each product page.
Name
Full legal name or registered trade name / trademark
Postal address
Full street address in an EU member state (P.O. box is not sufficient)
Electronic contact
Email address or contact form URL
Ecommerce stores: For online sales, the EU Responsible Person's information must be directly visible on each product page, or accessible via a clearly labelled link from the product page. It is not sufficient to include it only in a footer or terms page.
Enforcement
Penalties for non-compliance
Missing EU Responsible Person information is one of the most commonly cited GPSR violations. Consequences include:
Market withdrawal orders
Products can be banned from EU sale immediately if no EU Responsible Person is identifiable.
Fines up to €100,000
Germany imposes fines up to €100,000; other member states have comparable maximums. Fines are per product category, not per listing.
Marketplace account suspension
Amazon.de, Otto, Zalando and other EU marketplaces remove listings and suspend accounts that cannot provide EU Responsible Person details.
Criminal liability
Certain member states impose criminal liability on repeat offenders or in cases involving unsafe products.
FAQ
Common questions
Who needs an EU Responsible Person under GPSR?
Any business selling physical products to EU consumers that is based outside the European Union must appoint an EU Responsible Person. EU-based manufacturers, importers, and distributors fulfill this role themselves.
What is the difference between an EU Responsible Person and an EU representative?
They are the same role — GPSR Article 4 defines the EU Responsible Person as the manufacturer (if EU-based), the importer, or an authorised representative. The term "EU representative" is informally used to describe an authorised representative appointed specifically to fulfill this GPSR obligation.
Can a forwarding agent or logistics company be my EU Responsible Person?
No. A forwarding agent or logistics provider does not qualify. The EU Responsible Person must be a legal entity established in the EU that accepts liability for product safety compliance on behalf of the manufacturer.
What information must appear on the product or packaging?
The EU Responsible Person's name, registered trade name or trademark, and postal address must appear on the product, its packaging, or an accompanying document.
Related guides
Full GPSR Compliance Guide
Complete requirements and checklist for EU stores
EU Responsible Person — Blog
Practical breakdown of the EU representative requirement
Non-EU Sellers Guide
How to appoint a representative if you are outside the EU
GPSR for Shopify
Step-by-step guide for Shopify merchants
GPSR for WooCommerce
Step-by-step guide for WooCommerce merchants