GPSR Responsible Person vs Authorised Representative — what is the difference?

These two terms cause significant confusion because they describe similar roles from different pieces of EU legislation that often apply to the same product. Understanding the distinction matters for building correct compliance documentation and for knowing what to tell Amazon, Etsy, or EU customs when they ask for your EU contact information.

The EU Responsible Person is the concept introduced by Article 16 of Regulation (EU) 2023/988 (the GPSR). It is required for every non-food consumer product placed on the EU market — no exceptions for product type, sales volume, or company size. The Responsible Person must be physically established in the EU and is the primary point of contact for market surveillance authorities under the GPSR framework. Their obligations include holding the technical file, ensuring compliant labelling, cooperating with authority inspections, and reporting product risks through the Safety Business Gateway. The GPSR identifies four possible types of Responsible Person: the EU-based manufacturer (automatically), the EU importer, a formally designated authorised representative, or a fulfilment service provider established in the EU where no importer or representative exists.

The Authorised Representative (AR), by contrast, is a concept rooted in Regulation (EU) 2019/1020 on market surveillance and compliance of products, which applies to products subject to EU harmonisation legislation — the legislation that generates CE marking (Toy Safety Directive, Low Voltage Directive, Machinery Regulation, Radio Equipment Directive, and others). An AR is formally appointed in writing by the manufacturer and takes on specific legal tasks defined in that harmonisation legislation. The AR and the Responsible Person have substantially overlapping functions — both hold documentation, liaise with authorities, and ensure compliance — but they operate under different regulatory frameworks. Crucially, a company providing Authorised Representative services under Regulation 2019/1020 can simultaneously act as the GPSR Responsible Person, and this combined role is the standard commercial offering from most compliance service providers. For sellers on Amazon, both the AR and Responsible Person information may be requested, and in practice the same EU address satisfies both requirements when the provider covers both roles.

What the law says

Consequences of non-compliance