Question 1

What is an EU Authorized Representative (EU AR)?

Accepted Answer

An EU Authorised Representative (EU AR) is an EU-established entity that may act on behalf of a non-EU manufacturer under a written mandate. Whether an EU-based responsible economic operator is required depends on the product, applicable EU legislation and supply chain; an importer or manufacturer may fulfil that role in some cases.

Question 2

Do Amazon sellers need an EU Authorized Representative?

Accepted Answer

Not automatically. Whether an Amazon seller needs an EU-based responsible economic operator depends on the product, applicable EU legislation and supply chain. Amazon marketplace policies may request information or documents, but they do not replace EU legal obligations; product-specific assessment is required.

Question 3

What is a Digital Product Passport (DPP)?

Accepted Answer

A Digital Product Passport (DPP) is a digital record containing information about a product's materials, components, repairability, sustainability data, and certifications. Under EU Regulation 2024/1781 (ESPR — Ecodesign for Sustainable Products Regulation), DPPs will be mandatory for batteries from February 2027, and for textiles, electronics, and other categories in subsequent years.

Question 4

What is GPSR and when did it come into effect?

Accepted Answer

GPSR stands for General Product Safety Regulation (EU 2023/988). It replaced the older General Product Safety Directive and came into full effect on December 13, 2024. It applies to all physical consumer products sold in the EU, including products sold through online marketplaces by non-EU sellers.

Question 5

When is the battery passport mandatory in the EU?

Accepted Answer

Battery passports become mandatory in the EU from February 18, 2027, under EU Battery Regulation 2023/1542. All industrial batteries, EV batteries, and LMT batteries above 2 kWh placed on the EU market must have a Digital Product Passport (DPP) accessible via a QR code.

Question 6

Do Etsy sellers need an EU Authorized Representative?

Accepted Answer

The applicable EU requirement depends on the product, applicable legislation, supply-chain role and available evidence. GPSR may be relevant for covered consumer products. A responsible economic operator may be required in some cases, while an EU-established manufacturer or importer may fulfil the applicable role. Etsy marketplace requests do not replace product-specific EU legal assessment.

Question 7

What is the difference between a GPSR Responsible Person and an EU Authorized Representative?

Accepted Answer

A GPSR Responsible Person under Regulation (EU) 2023/988 and an EU Authorised Representative are distinct legal concepts. Under GPSR, the applicable role is the Responsible Person. Some marketplaces may use different terminology in their interfaces, but this does not make the legal roles equivalent.

EU Compliance for Cosmetics & Personal Care

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