Who can be the EU Responsible Person under GPSR?

One of the most significant changes introduced by Regulation (EU) 2023/988 is the requirement for every non-food consumer product placed on the EU market to have an identifiable economic operator physically established within the European Union. This person or entity — commonly referred to as the «EU Responsible Person» or «Responsible Person» — serves as the official compliance contact for EU market surveillance authorities and must be identifiable from the product label, packaging, or accompanying documents.

Article 16 of the GPSR sets out four categories of entity that can legally serve as the Responsible Person. The first is the EU-based manufacturer: if the manufacturer is established within the EU, it automatically acts as the Responsible Person and no additional designation is needed. The second is the EU importer: when the manufacturer is based outside the EU, the importer who first places the product on the EU market becomes the Responsible Person by default. The third is the authorised representative: a non-EU manufacturer can formally designate, in writing, an EU-based representative to act as the Responsible Person. The fourth is the fulfilment service provider: in direct-to-consumer online sales where neither an importer nor an authorised representative is identified, an EU-based fulfilment service provider can take on the role.

Whichever entity acts as Responsible Person has concrete obligations: verifying product compliance before market placement, holding the technical file and keeping it current, ensuring correct labelling including their own contact details, cooperating with authorities during inspections, and notifying the Safety Business Gateway in the event of a serious product risk. Their name, postal address, and electronic address must appear on the product, its packaging, or an accompanying document — and must also be displayed on online listings under Article 19.

What the law says

Consequences of non-compliance