A UK seller GPSR responsible person EU review is needed when a business established in Great Britain sells consumer products into the European Union. You must establish whether an EU-based economic operator is identified for each product before it is placed on the EU market. The right operator depends on the product, supply chain and any sector-specific rules.
Key takeaways
- A business established in Great Britain is established outside the European Union for the purposes of Regulation (EU) 2023/988.
- For relevant products sold in the EU, an economic operator established in the Union must be identifiable before the product is placed on the market.
- A GPSR responsible person, a CE authorised representative and an importer are distinct roles with different conditions and duties.
- An online product offer must show the GPSR safety and traceability information required for distance sales.
- EORI, VAT and customs clearance are separate obligations from product compliance.
Does a UK seller need a GPSR responsible person in the EU?
A seller established in Great Britain should assess whether an EU-established economic operator exists for every consumer product offered on the EU market. Where no manufacturer, importer or other qualifying operator is already established in the Union for the product, a GPSR responsible person may be needed.
Regulation (EU) 2023/988 on general product safety, known as the GPSR, has applied since 13 December 2024. It governs the safety of consumer products where sector-specific legislation does not fully address the relevant risk, or where the GPSR supplements that legislation.
Do not decide this solely from your trading address. First identify the actual manufacturer, where it is established, the entity physically importing goods into the Union, and the rules applying to the product category. If you buy in China, hold stock in the UK and send directly to a consumer in France, your UK company is not EU-established simply because the customer is in France.
A GPSR responsible person is an economic operator established in the Union that performs the duties assigned to it under the Regulation for the products concerned. This includes being able to cooperate with market-surveillance authorities and to act on risks or corrective measures within its role. The general duties of economic operators are set out in Article 16 of Regulation (EU) 2023/988.
Before appointing anyone, use an EU market-entry compliance assessment if you need to map your products, storage countries and trade flows. It helps identify points to check, including GPSR, CE marking, VAT, EORI and extended producer responsibility schemes.
EU Seller Kit — The EU GPSR responsible person service is for non-EU sellers that need an EU-established economic operator for consumer products. It becomes active only after product review, entity assignment, a signed mandate and active payment.
Why is Great Britain treated as outside the EU for this purpose?
For sales from Great Britain into the Union, the UK is not an EU Member State. A company established in England, Scotland or Wales is therefore a non-EU business under the GPSR and under EU customs rules.
That distinction has a practical consequence: a UK address does not meet an EU-establishment requirement where legislation requires an economic operator in the Union. It does not matter whether your shop is in French, you charge in euros, or you sell through Amazon, eBay, Etsy or your own website.
Example: a British decorative-lamp brand ships from Birmingham to Germany. Even if it has a German VAT number or sells in euros, it remains UK-established. It must therefore check both the economic operator required for the product and the CE rules that apply to electrical equipment.
Take particular care with Northern Ireland. Rules and identifiers for some movements can differ from those applicable to Great Britain. If goods move between Great Britain, Northern Ireland and the EU, consult the guide to GB and XI EORI numbers and confirm the treatment of your transaction with the relevant authority or a qualified adviser.
The GPSR does not replace sector-specific legislation. A toy, radio device, cosmetic or textile product may be subject to additional rules. Toys, for example, fall under Directive 2009/48/EC on the safety of toys, while radio equipment is covered by Directive 2014/53/EU on radio equipment. Check the required role and documents product by product.
Which products and economic operators are covered?
Consumer products made available in the Union, including through online sales, should be assessed under the GPSR. The economic operator to identify may be the manufacturer, importer, authorised representative where the applicable law permits it, or a responsible person appointed under the relevant framework.
“Placing on the market” means the first making available of a product on the Union market in the course of commercial activity. A shipment from the UK to an EU consumer can therefore fall within scope. Selling in small volumes or through a marketplace does not automatically remove the obligations.
Start by identifying the real supply chain
For each SKU, gather answers to the following:
- who manufactures the product and where that manufacturer is established;
- who applies the brand or has the product made under its brand;
- who brings the goods physically into the Union;
- where stock is held before sale;
- which EU countries you target; and
- whether the product is subject to CE legislation, cosmetics, textiles, toys, batteries or another specific regime.
Imagine a US manufacturer shipping kitchen accessories to your UK company. You then sell them to consumers in Spain. If no actor in the chain is established in the EU for the products concerned, you need to assess the appointment of an EU-established operator before marketing them.
A common mistake is to assume that the marketplace automatically becomes responsible for every product. A marketplace may impose contractual data and checking requirements, but that does not automatically transfer your regulatory responsibilities. To review visible traceability, safety and compliance details before publication, use the marketplace product compliance scanner.
Check category-specific rules as well
The GPSR provides a general safety baseline. It does not remove sector-specific obligations. Cosmetics, for example, are governed by Regulation (EC) No 1223/2009 on cosmetic products, which has its own responsible-person regime. Textile products must also meet fibre-composition and labelling requirements under Regulation (EU) No 1007/2011.
If you do not know which legislation applies, do not infer the answer from the product’s appearance or a supplier’s claims. Request technical documents, relevant reports and instructions. Supplier Check helps you centralise supplier identity, payment and delivery information so that inconsistencies can be reviewed before you order.
What is the difference between a GPSR responsible person, CE authorised representative and importer?
These roles are not interchangeable. A GPSR responsible person performs duties under the general product-safety rules, a CE authorised representative acts under a written mandate where applicable CE legislation permits it, and an importer is the actor placing a product from a third country on the EU market.
| Role | When it applies | Do not assume |
|---|---|---|
| GPSR responsible person | For GPSR products where an EU-established operator must be identified | That a SaaS subscription automatically appoints this person |
| CE authorised representative | For certain CE products, under sector-specific law and a written mandate | That it replaces the manufacturer’s conformity assessment |
| Importer | When it places a third-country product on the EU market | That it is always the online seller or marketplace |
CE marking applies only to product groups covered by EU harmonisation legislation. It is not a mark for every consumer product. Where it is required, the manufacturer remains responsible for conformity assessment, technical documentation, necessary testing and the EU declaration of conformity. The official Your Europe guidance on CE marking confirms this principle.
A CE authorised representative may be relevant to a non-EU manufacturer of CE-marked products, but only where the applicable legislation permits the role and after a written mandate is in place. It does not replace testing, the technical file or the manufacturer’s EU declaration of conformity. For a fuller distinction, read the guide to the CE authorised representative’s role and limits.
Conversely, a GPSR responsible person does not become the manufacturer of your product. It cannot cure an unsafe product, incomplete labelling or missing documentation. If an authority requests information or corrective action, poor preparation can lead to a withdrawal request, suspended sales or a blocked marketplace listing.
What must you show on online listings for EU sales?
Distance-sales offers must give consumers the required safety and traceability information before purchase. For products in scope, the online listing must make it possible to identify the product, manufacturer and, where relevant, the EU-established economic operator.
Article 19 of Regulation (EU) 2023/988 sets information requirements for distance-sale offers. Depending on the product, prepare at least:
- the manufacturer’s name or registered trade mark, postal address and electronic address;
- where the manufacturer is not established in the EU, the contact details of the responsible person established in the Union;
- product identification, such as an image, type or other identifier; and
- warnings and safety information needed for the product, in a language easily understood by consumers in the target market.
Information shown online does not necessarily replace information required on the product, its packaging or an accompanying document. What is feasible depends on the product’s nature, size and characteristics. Keep the label, instructions, marketplace listing and technical documents strictly consistent.
Example: you sell a hairdryer from London to customers in France. Attractive images and sales copy are not enough. You must check the applicable electrical-product rules, warnings, identification and details of the relevant operator, as well as the information required on the sales page. For a practical method, see GPSR distance-sales listing requirements.
A common mistake is adding the name of an EU entity without a mandate or product assignment. That can create misleading information and does not show that the operator has accepted the relevant duties. The appointment must be real, documented and aligned with the products actually covered.
How do EORI, VAT and customs apply to shipments from Great Britain?
A GPSR responsible person does not replace EORI, customs formalities or VAT arrangements. Whenever goods cross the border between Great Britain and the Union, you must separately organise the customs declaration, declared importer, value, tariff classification and VAT treatment.
An EORI number identifies operators in their dealings with EU customs authorities. The rules sit within the Union Customs Code, Regulation (EU) No 952/2013, supplemented for EORI by Implementing Regulation (EU) 2015/2447. A GB EORI obtained from HMRC serves a UK customs purpose; it is not automatically an EORI issued in the Union. UK application arrangements are set out by GOV.UK: Get an EORI number.
If you send stock from Shenzhen to an Amazon FBA warehouse in Germany, the issue is no longer only a consumer sale. You need to determine who imports, which EORI is required, where import VAT is due and which obligations arise from local storage. The guide to when you need an EU and GB EORI helps distinguish the identifiers by trade flow.
Prepare the data before dispatch
The HS or TARIC code, origin, customs value and Incoterm affect the declaration and costs. Wrong classification can distort duty calculations, applicable measures and requested documents. Use the HS classification assistant to generate candidate subheadings, then confirm them in TARIC or with a specialist where the commercial risk justifies it.
VAT depends in particular on the import country, storage location, sales model and, where relevant, OSS or IOSS. The European Commission explains the one-stop-shop schemes through its VAT One Stop Shop portal. To compare common import, domestic and intra-EU VAT scenarios, use the EU VAT calculator.
EU Seller Kit — Prepare an EORI application file when you need a number for customs operations; the customs authority issues the number, while file preparation is a one-off service unless included in a plan quota. To structure known import costs, the customs cost simulator calculates duties only where a valid tariff rate is available.
Checklist: how do you sell from the UK into the EU?
Use this checklist before publishing a new SKU or sending stock into the EU. It does not replace analysis of sector-specific rules or discussion with the competent authority where a product presents risk, uses regulated technology or involves a complex logistics arrangement.
- Identify the actual manufacturer, brand owner, seller, importer and storage locations for each SKU.
- Decide whether the product is subject only to the GPSR or also to sector-specific rules, including CE, toys, cosmetics, textiles, batteries or electrical equipment.
- Confirm that an EU-established economic operator is correctly identified for relevant products and that its role is documented.
- Gather proportionate safety evidence, risk assessment, instructions, warnings and technical documents for the product.
- Check that the label, packaging, instructions and sales listing contain consistent information suitable for each target country.
- Review distance-sale information before publication, including manufacturer details and, where applicable, the EU responsible person’s details.
- Define the declared importer, appropriate EORI, tariff code, customs value and VAT treatment before dispatch.
- Review additional national obligations, including packaging, WEEE, batteries and sorting labels in destination countries.
The point most often missed is consistency between teams. Procurement holds supplier documents, logistics prepares the customs declaration, and ecommerce publishes the listing. Yet one incorrect address or missing warning on a listing can trigger a marketplace correction request or an enquiry from an authority.
For sales across several countries, Country Compliance helps organise customs, tax and product checks by origin, storage and destination country. If you send stock into the Union before selling it, pair this work with the EU stock import guide for ecommerce sellers.
Tools and services to take action
- EU Market Entry Compliance Assessment — Use it before a first shipment or a new trade flow to build a plan for checking EORI, VAT, GPSR, CE and related obligations.
- GPSR Responsible Person (EU) — Use this service where a non-EU seller needs an EU-established economic operator for consumer products, subject to review, assignment, signed mandate and active payment.
- CE Authorised Representative — Consider it for a non-EU manufacturer of CE products where the applicable legislation permits the role and a written mandate is appropriate.
- Marketplace Product Compliance Scanner — Use it before publishing an Amazon, eBay, Etsy, Shopify or other listing to flag traceability, safety and compliance information to check.
- EU Seller Kit pricing and plans — Review SaaS plans and add-on services without assuming that a subscription itself appoints a representative.
Frequently asked questions
Does a UK Amazon seller have to show an EU responsible person?
Where the GPSR requires an EU-established economic operator for the product and no other qualifying operator is already in place, the responsible person’s details must be available in accordance with the applicable rules, including in the distance-sale offer. Amazon may also request this data through its compliance processes. Check the supply chain and product category before entering an address.
Is a German returns address enough for GPSR compliance?
No. A returns address or logistics provider in Germany is not automatically a GPSR responsible person. The relevant entity must be established in the EU, accept the applicable role and be correctly assigned to the products concerned.
My Chinese supplier already has CE marking. Do I still need to check GPSR?
Yes. CE marking alone does not show that all GPSR, traceability, online-information or economic-operator obligations have been met. You should also confirm that the product genuinely falls under the CE legislation claimed, that documentation is available and that all additional requirements are met.
Can a GPSR responsible person sign my EU declaration of conformity?
Not automatically. The EU declaration of conformity remains a manufacturer responsibility under the applicable sector-specific rules; an authorised representative may carry out certain tasks only within the limits of a written mandate and the relevant legislation. A GPSR responsible person does not remove the manufacturer’s duties for conformity assessment, testing or technical documentation.
Do I need an EU EORI if I only ship directly from the UK?
It depends on who completes the customs formalities and how the import is organised. A carrier or customs representative may be involved, but you should determine the importer, declarations and identifiers required before dispatch. Do not confuse an EORI with a VAT number or the contact details of a GPSR responsible person.
Does the GPSR apply to second-hand products?
The Regulation generally covers products made available on the market in the course of commercial activity, subject to nuances based on the product and any specific rules that apply. A used product sold by a professional should not be presumed exempt without checking. Review its condition, history, available safety information and any sector-specific requirements.
Official sources
- Regulation (EU) 2023/988 — General Product Safety Regulation — Sets the GPSR framework, economic-operator duties and distance-sales information requirements.
- Directive 2009/48/EC — safety of toys — Covers sector-specific requirements for toys placed on the EU market.
- Directive 2014/53/EU — radio equipment — Covers requirements for relevant radio and connected equipment.
- Regulation (EC) No 1223/2009 — cosmetic products — Sets the specific cosmetics regime, including the responsible person.
- Regulation (EU) No 1007/2011 — textile fibre names and labelling — Covers fibre-composition and labelling requirements for textile products.
- Your Europe — CE marking — Explains CE-marking principles and manufacturer responsibilities.
- Regulation (EU) No 952/2013 — Union Customs Code — Governs customs formalities for trade with the Union.
- Implementing Regulation (EU) 2015/2447 — UCC implementing provisions — Includes implementing rules relevant to EORI.
- GOV.UK — Get an EORI number — Explains how to apply to HMRC for a UK EORI number.
- European Commission — VAT One Stop Shop — Explains OSS and IOSS schemes for cross-border VAT.
This content provides general information and is not legal advice.