EU responsible person: who can act for you and what they do
When a manufacturer is outside the EU, the GPSR and the Market Surveillance Regulation require an economic operator established in the EU to be responsible for each product. Sellers often call this person an “EU responsible person” or “EU representative”.
Who can be the responsible person
In order of priority:
- The manufacturer, if it is established in the EU.
- An importer established in the EU — the business that places your product on the EU market.
- An authorised representative — a business in the EU you appoint in writing to act for you.
- A fulfilment service provider — a business that stores, packs and ships your products in the EU, when none of the above exists.
Most non-EU sellers on marketplaces use an authorised representative, because they import directly to customers and have no EU importer.
What the responsible person must do
- Check that the EU declaration of conformity (where one is required) and technical documentation exist, and keep them available for the authorities.
- Give authorities the information and documents they ask for, in a language they understand.
- Tell the authorities when they have reason to believe a product presents a risk.
- Cooperate on corrective action, such as a recall.
They are not a substitute for safe design and testing. They are the point of contact the authorities can reach inside the EU.
Where their details must appear
The responsible person’s name, registered trade name or mark, and contact details including postal address must be on the product, its packaging, the parcel or an accompanying document — and in every online listing. The GPSR label generator adds them for you.
How to choose a provider
- Scope: which product categories and countries they cover, and whether they also offer packaging EPR or WEEE registration.
- Documents: will they review your technical documentation, or only hold it?
- Response: how quickly they answer authority requests and how they tell you.
- Contract: a written mandate that names the products, your obligations and theirs, and how either side can end it.
- Price: fees vary widely by number of products and categories. Compare what is included.
We can introduce you to vetted providers: find a provider.
Cosmetics are different
Cosmetics are covered by Regulation (EC) No 1223/2009, not the GPSR. They need a responsible person under the Cosmetics Regulation, who handles the product information file, safety assessment and notification in the CPNP portal.
Frequently asked questions
Can a marketplace act as my responsible person?
Usually not by default. A marketplace is not your importer or representative unless it has agreed to be. Some fulfilment programmes offer this, so check the contract.
Is the cosmetics responsible person the same thing?
No. Cosmetics need a responsible person under the Cosmetics Regulation, with its own duties such as the product information file and CPNP notification. Some providers offer both.
Sources
- Regulation (EU) 2019/1020 on market surveillance, Article 4
- Regulation (EU) 2023/988 on general product safety (GPSR), Article 16
- Regulation (EC) No 1223/2009 on cosmetic products
ohdock provides software tools and general information, not legal advice. Check the official texts, or ask a qualified adviser, for your situation.