A GPSR responsible person is the EU-based company that answers to the authorities for a consumer product under Regulation (EU) 2023/988, and without one the product may not be placed on the EU market.
For a seller outside the EU, that is usually its importer or an authorised representative. Below is what the role involves, who can take it, how to set one up and where its details go.
Despite the name, the responsible person is rarely a person. It is an EU-based company with legal tasks, and a different role from the authorised representative many sellers already have for EPR.
Where your company is based decides who takes the role.
Is your company established in the EU?
Pick your answer below for the right guidance.
Key facts about the GPSR responsible person
Below are the six facts that define the role.
| Topic | In short |
|---|---|
| The law | Article 16 of GPSR, Regulation (EU) 2023/988 |
| Since | 13 December 2024 |
| Products | All consumer products under GPSR, including online sales from outside the EU |
| Who | An EU manufacturer, the importer, an authorised representative or, as a last resort, a fulfilment service provider |
| Tasks | Keeps the paperwork ready, answers the authorities, reports risks, helps with recalls and checks the product regularly |
| Where | The product, its packaging, the parcel or a document that comes with it, plus every online listing when the maker is outside the EU |
The facts follow EUR-Lex's record of the General Product Safety Regulation and EUR-Lex's record of the Market Surveillance Regulation, both in their newest consolidated versions.
What the role covers from shipment to recall
Article 16(1) of GPSR gives the responsible person the four tasks in article 4(3) of the Market Surveillance Regulation (MSR), and article 16(2) adds regular checks. Together they follow the product through its life on the market.
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Before it is sold
Check that the manufacturer has drawn up the technical documentation and that it can be handed to the authorities on request (MSR article 4(3)(a)).
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While it is on sale
Check regularly that the product matches its technical documentation and carries its type or batch number, the manufacturer's details and instructions in the right language (GPSR article 16(2)).
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When an authority asks
Give the market surveillance authority, after a reasoned request, every document it needs to see the product is safe, in a language it easily understands (MSR article 4(3)(b)).
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When there is a risk
Inform the authorities when there is reason to believe the product presents a risk, and cooperate on the corrective action, up to a withdrawal or recall (MSR article 4(3)(c) and (d)).
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After an accident
When the manufacturer is outside the EU, make sure an accident that caused a death or serious harm is reported through the Safety Business Gateway (GPSR article 20(4)).
The regular checks need a paper trail. Authorities can ask the responsible person for documented evidence of the checks it has carried out (article 16(2)), so they have to be written down, not just done.
Products that need a responsible person
Article 16 applies to every product GPSR covers, and the full guide to what GPSR is sets out that scope in detail. In short, it is any product meant for consumers or likely to be used by them, new or used, sold or given away by a business (articles 2(3), 3(1) and 3(6)).
An online offer aimed at EU consumers counts as making the product available in the EU (article 4), so selling from a shop outside the EU does not take a product out of scope.
Food, feed, medicines, living plants and animals, plant protection products and antiques are outside GPSR altogether (article 2(2)).
CE-marked products follow a different article
For products under the EU laws behind CE marking, article 16 of GPSR does not apply (article 2(1)(b)). The role does not disappear for them, though.
Article 4 of the Market Surveillance Regulation requires the same kind of EU-based company for products under the laws it lists in article 4(5).
Among them are the Toy Safety Directive 2009/48/EC, RoHS 2011/65/EU, the Low Voltage Directive 2014/35/EU, the Radio Equipment Directive 2014/53/EU and the Battery Regulation (EU) 2023/1542.
The same four companies can take the role there, with the same four tasks. The regular checks and the email address on the product are additions that come from GPSR.
Four companies that can take the role
Article 4(2) of the Market Surveillance Regulation names four kinds of company, and GPSR applies the same list (article 16(1)).
| Company | When it can be your responsible person |
|---|---|
| Manufacturer established in the EU | When it makes the product, or has it made, and sells it under its own name |
| Importer | When the manufacturer is outside the EU and the importer brings the product onto the EU market |
| Authorised representative | When the manufacturer has given it a written mandate for the responsible person's tasks |
| Fulfilment service provider | Only for the products it handles, and only when none of the three others is established in the EU |
A fulfilment service provider is a company that offers at least two of warehousing, packaging, addressing and dispatching without owning the goods. Postal, parcel delivery and freight transport services do not count (GPSR article 3(12)).
Who takes the role in your case
Established in the EU. If your company makes the product, or has it made and sells it under its own name, the role is yours. If you import a product made outside the EU, it sits with you as the importer.
Selling from outside the EU. If an EU company buys your goods and brings them into the EU, that importer can be your responsible person. If you ship straight to EU consumers, there is often no EU importer in the chain, so you appoint an authorised representative with a written mandate.
A fulfilment service provider only takes the role when neither of those exists, and only for the goods passing through its hands.
How to set up a GPSR responsible person
The six steps below take a manufacturer outside the EU from no responsible person to one that is named on every product and listing. An EU manufacturer or importer already holds the role and can start at step 4.
Step 1. Check that GPSR covers the product
Start with the product, not the company. Three checks settle it.
- Consumer product. It is meant for consumers or likely to be used by them, and it is not food, feed, medicine or another excluded category (articles 2 and 3).
- Offered in the EU. It is sold in the EU or offered online to EU consumers (article 4).
- No CE law. A product under a CE law follows article 4 of the Market Surveillance Regulation instead, with the same role.
If all three hold, article 16 of GPSR applies and the product needs a responsible person before it goes on sale.
Step 2. Pick the company that will take the role
Start with who is already in your supply chain. If an EU importer buys your goods, it can carry the role. If not, or if you prefer a specialist, appoint an authorised representative.
Relying on a fulfilment service provider is narrow by design. It only qualifies for the goods it stores or ships, so anything sent from another warehouse still needs someone else.
Whoever you pick must have the means to do the work (MSR article 5(3)). Ask how they would answer an authority's request in each country you sell in, and who would handle a recall.
Step 3. Sign a written mandate
An authorised representative only takes the role through a written mandate from the manufacturer that names it for the responsible person's tasks (MSR article 4(2)(c)). The mandate is what links a manufacturer outside the EU to the authorities inside it.
Under GPSR article 10(2) the mandate must allow the representative at least these four tasks.
- Give an authority information and documents on its reasoned request, in an official language that authority understands
- Tell the manufacturer when it believes the product is dangerous
- Notify the authorities through the Safety Business Gateway about action taken against a risk, when the manufacturer has not already done so
- Cooperate with the authorities on any action to remove the risk
The representative must show a copy of the mandate to the authorities when they ask for it (article 10(2)), so keep the signed version where both of you can find it.
Step 4. Give them what the tasks need
The responsible person can only check and answer for what it can see. Before the first shipment, give it access to these three things.
- The technical documentation, meaning the risk analysis and product description you drew up under article 9(2)
- The labels and instructions for every language version, so the regular checks under article 16(2) have something to compare against
- A line for safety news. The manufacturer must keep responsible persons informed in good time of any safety issue it finds (article 9(10)), so agree who tells whom and how fast
Agree at the same time who files an accident report through the Safety Business Gateway, because when the manufacturer is outside the EU the responsible person must make sure it is filed (article 20(4)).
Step 5. Put their details on the product
The responsible person's name, registered trade name or trade mark, postal address and email address go on the product, its packaging, the parcel or an accompanying document (article 16(3)). One of the four is enough.
The listing is the one place on top of the physical four. A buyer online cannot read a label, so the law puts the same details on screen, as the next step explains.
Step 6. Name them in every online listing
When the manufacturer is outside the EU, every online offer must show the responsible person's name, postal address and email address clearly and visibly (article 19(b)).
Online marketplaces must build their seller interface so the trader can enter those details for each product, and must show them on the product listing (article 22(9)). The field is there, but filling it in is the seller's job.
Check each marketplace and each country version of a listing, since one missing field is enough for the offer to fall short of article 19.
Since when sellers have needed one
The EU-based responsible company arrived in two stages, first for CE products and then for everything GPSR covers.
- 16 July 2021. Article 4 of the Market Surveillance Regulation started to apply, requiring an EU-based responsible company for CE products under the laws it lists (MSR article 44).
- 13 December 2024. GPSR started to apply and extended the same requirement to the consumer products it covers (articles 16 and 52).
The one amendment to GPSR so far, Regulation (EU) 2024/2748, has applied since 29 May 2026. It adds emergency procedures and leaves the articles on the responsible person unchanged.
Fines and enforcement without a responsible person
Article 16(1) is a condition for sale. A product covered by GPSR may not be placed on the EU market until a company established in the EU has taken on the role.
GPSR sets no fine of its own. Each EU country lays down its own penalties, which must be effective, proportionate and dissuasive (article 44), so the amount depends on the country where the breach is found.
National market surveillance authorities enforce the rules, and they can order an online marketplace to take down an offer (article 22). The quickest check you can make today is to open one of your listings and see whether it names an EU company with a postal and email address.
Where Repax fits next to GPSR
A responsible person covers product safety. The same products also carry EPR duties for their packaging, and for any electronics or batteries inside them, in each country where they are sold, from registration to regular reporting, as the guide to EPR registration in Europe explains.
Some countries also require a seller without a local company to appoint an authorised representative for those EPR duties. That is a separate appointment under national law, explained in the guide to appointing an EPR authorised representative.
Do you also need EPR registrations in the EU? Repax Comply runs your EPR registrations market by market, with an authorised representative where one is required. Explore ComplyRepax does not act as a GPSR responsible person and does not keep technical documentation. That role stays with your importer or the authorised representative you appoint.
Frequently asked questions about the GPSR responsible person
Below are the eight questions sellers ask most often about the GPSR responsible person.
What is a GPSR responsible person?
It is the company established in the EU that answers to the authorities for a consumer product under GPSR, Regulation (EU) 2023/988. Article 16 bars the product from the EU market until such a company exists, and its details must appear on the product.
Do I need a GPSR responsible person if I sell from outside the EU?
Yes, if your product falls under GPSR and is offered to EU consumers. Your EU importer can take the role. If you have none, appoint an authorised representative with a written mandate, and name it in every online listing.
Is a GPSR responsible person the same as an authorised representative?
Not quite. An authorised representative is one of four kinds of company that can be the responsible person. An EU manufacturer, an importer or, as a last resort, a fulfilment service provider can also take the role, and only the representative needs a mandate.
Can a fulfilment service provider be my GPSR responsible person?
Only in a narrow case. It takes the role for the products it handles, and only when no EU manufacturer, importer or authorised representative exists for them. An online marketplace is not on the law's list of companies that can take the role.
Where must the responsible person's details appear?
Their name, postal address and email address go on the product, its packaging, the parcel or an accompanying document, under article 16(3). When the manufacturer is outside the EU, the same details must also appear in every online offer, under article 19.
What must the written mandate for a GPSR responsible person say?
It must name the authorised representative for the responsible person's tasks. Under GPSR article 10, it must at least let them hand authorities documents, warn the manufacturer about danger, notify the Safety Business Gateway and cooperate on removing risks.
Does a CE-marked product need a GPSR responsible person?
Not under GPSR article 16, which does not apply to products under CE laws. For most of them, though, article 4 of the Market Surveillance Regulation requires the same EU-based company, with the same core tasks and the same list of candidates.
Is the GPSR responsible person the same as an EPR authorised representative?
No. The GPSR responsible person answers for product safety under EU law. An EPR authorised representative handles registration and reporting of packaging, electronics or batteries under one country's law, so appointing one does not cover the other.
