Can I be my own EU Responsible Person under GPSR?
Yes — but only if your business is established within the European Union or the European Economic Area. Article 16 of Regulation (EU) 2023/988 lists the entities that can act as the EU Responsible Person, and the common thread is EU establishment. If you are a manufacturer or importer physically based in a Member State — France, Germany, Spain, Italy, the Netherlands, Poland, or any of the 27 EU countries — you automatically fulfil the Responsible Person requirement for products you manufacture or import. You do not need to designate a separate third-party service; you simply use your own business name and address. The same applies to businesses based in Norway, Iceland, and Liechtenstein, which are EEA members but not EU Member States and are covered by the GPSR through the EEA Agreement.
Being your own Responsible Person is straightforward in terms of designation — no paperwork is required beyond ensuring your own contact details appear correctly on the product. But it is emphatically not a passive role. The obligations attached to the Responsible Person under the GPSR are active and ongoing: you must hold and maintain the complete technical file for each product for 10 years from the last sale; ensure the product is correctly labelled with your name, postal address, and electronic address; verify compliance before each new product is placed on the market; cooperate fully with any market surveillance inspection and produce the technical file within 10 days of request; and report serious product risks and accidents through the Safety Business Gateway under Article 20.
UK-based businesses are in a different situation after Brexit. The United Kingdom left the EU in January 2020, and UK-registered entities are no longer considered EU-established for GPSR purposes. A UK company selling to EU consumers cannot use its UK address as the EU Responsible Person — it must designate a separate entity established in an EU Member State. This applies whether the UK company is the manufacturer, importer, or a reseller. The only exception relates to Northern Ireland, which has a complex status under the Windsor Framework, but in practice most product categories still require an EU-established Responsible Person even for goods entering Northern Ireland.
What the law says
Article 16.1 of Regulation (EU) 2023/988 requires an economic operator established in the EU to be the Responsible Person for every product placed on the EU market. EU-based manufacturers and importers fulfil this requirement automatically. Their contact details must appear on the product per Article 9.6.
Consequences of non-compliance
Acting as your own Responsible Person without the technical file ready is an infringement even if you are EU-based. Designating yourself but failing to produce documentation within 10 days of an authority's request exposes you to fines of up to €100,000 and potential listing deactivation on all EU platforms.
Whether you act as your own Responsible Person or designate one, GPSRCheck gives you the complete technical file you need to back that role — risk assessment, Declaration of Conformity, labelling checklist. €49 per product.
Generate your Technical File → €49