Responsible Person under GPSR: Who Needs One and What They Do (2025)

What is a Responsible Person under GPSR?

The General Product Safety Regulation (GPSR, EU 2023/988), which came into full effect on 13 December 2024, introduced a new concept into EU product safety law: the Responsible Person.

A Responsible Person is an economic operator established in the EU who takes legal responsibility for ensuring that a consumer product complies with EU product safety requirements. For non-EU manufacturers, the Responsible Person is the EU-based entity they designate to act on their behalf.

Definition from GPSR Article 3(14): "Responsible person" means any natural or legal person established in the Union who ensures that the product in relation to which they perform a task is in compliance with the applicable Union harmonisation legislation or, in the absence of such legislation, with this Regulation.

Responsible Person vs EU Authorized Representative: What is the Difference?

The terms are often used interchangeably, and in practice they refer to the same role. The distinction is regulatory context:

Under GPSR, the Responsible Person can be:

• The EU-based manufacturer (if the manufacturer has an EU establishment)
• The EU importer (if the manufacturer is outside the EU)
• A designated EU Authorized Representative (if neither manufacturer nor importer is EU-based)
• The EU-based distributor (in specific circumstances, if they modify the product or place it under their own name)

For most non-EU sellers on Amazon, Etsy, or Shopify, the Responsible Person will be a designated EU AR service provider like AuraDPP.

What Are the Obligations of a Responsible Person?

Under GPSR Article 16, the Responsible Person must:

1. Verify product safety documentation — ensure the technical documentation, risk assessment, and safety information are available and complete
2. Maintain contact information on the product — name, registered address, and contact details must appear on the product or its packaging
3. Cooperate with market surveillance authorities — respond to requests for information, provide documentation, and assist with investigations
4. Take corrective action — if a product is found to be unsafe, the Responsible Person must cooperate with recall procedures and corrective measures
5. Register products in the Safety Gate — for certain high-risk products, registration in the EU Safety Gate portal may be required

The Responsible Person is the primary point of contact for EU authorities. If a product causes harm or is found to be non-compliant, authorities will contact the Responsible Person first.

Who Needs a Responsible Person?

Any non-EU seller shipping consumer products to EU buyers needs a Responsible Person. This includes:

• Amazon FBA sellers shipping to EU fulfillment centres (DE, FR, IT, ES, PL, NL, SE, etc.)
• Etsy sellers shipping handmade or vintage goods to EU buyers
• Shopify store owners with EU customers
• Chinese manufacturers exporting directly to EU consumers
• US, UK, Canadian, Australian, Turkish, Pakistani, and other non-EU sellers
• Dropshippers whose suppliers are outside the EU

There is no exemption for small sellers, handmade goods, or low-price items. GPSR applies to all consumer products regardless of value.

What Information Must Appear on the Product?

The Responsible Person's details must be visible on the product or its packaging:

• Full legal name of the Responsible Person (company name or individual name)
• Registered address in an EU member state
• Contact details — email address or phone number

This information must be:

• Printed on the product label, packaging, or instruction manual
• Included in the Amazon product listing (Manufacturer/Importer field)
• Included in Etsy shop policies and product descriptions
• Accessible to consumers before purchase

GPSR Enforcement: What Happens Without a Responsible Person?

EU market surveillance authorities have significant enforcement powers under GPSR:

• Marketplace delistings — Amazon, Etsy, and other platforms are required to remove listings that do not comply with GPSR
• Customs holds — EU customs authorities can hold shipments that lack compliant labelling
• Fines — EU member states set their own fines, which can reach €50,000 or more for serious violations
• Product recalls — authorities can order mandatory recalls of non-compliant products
• Import bans — repeated violations can result in import bans for specific products or sellers

Amazon began enforcing GPSR Responsible Person requirements in 2024 and has deactivated thousands of listings from non-compliant sellers.

How to Appoint a Responsible Person

To appoint a Responsible Person under GPSR, you need:

1. A written mandate — a formal agreement between you (the manufacturer or seller) and the EU-based Responsible Person, specifying the products covered and the representative's obligations
2. Product documentation — safety information, risk assessment, and technical documentation for each product
3. Label update — add the Responsible Person's details to your product label or packaging

The mandate must be kept on file and provided to EU authorities on request. It should specify:

• The full legal names and addresses of both parties
• The products covered (by product name, model, or category)
• The obligations of the Responsible Person
• The duration of the agreement
• Governing law and jurisdiction

AuraDPP provides Responsible Person services including the written mandate, label text, and documentation support. View pricing →

Frequently Asked Questions

Is the Responsible Person the same as the importer? Not necessarily. An EU-based importer can serve as the Responsible Person, but many importers decline this role because of the legal liability. A designated EU AR service provider is often a better option.

Can I use my EU customer's address as the Responsible Person? No. The Responsible Person must be a legal entity (company) or individual who has formally agreed to take on the legal obligations. You cannot use a customer's address without their explicit written consent and a formal mandate.

Does the Responsible Person need to be in the same EU country as my customers? No. One Responsible Person registered anywhere in the EU covers all 27 EU member states.

What is the difference between GPSR and CE marking requirements? GPSR applies to all consumer products. CE marking applies to specific product categories covered by EU harmonisation legislation (electronics, toys, machinery, etc.). Many products require both GPSR compliance and CE marking.

How long does it take to appoint a Responsible Person? With AuraDPP, the mandate can be completed within 1–2 business days. You will receive the label text, mandate document, and all documentation needed for your Amazon listing.