EU representation · Comparison
GPSR Responsible Person or CE Authorised Representative: which do you need?
A GPSR Responsible Person is the EU-established economic operator that Article 16 of Regulation (EU) 2023/988 requires before a consumer product is placed on the market. A CE Authorised Representative is the EU-established person a manufacturer appoints by written mandate under harmonisation legislation (toys, radio equipment, low voltage…). For a CE-marked product, an authorised representative whose mandate covers the tasks in Article 4 of Regulation (EU) 2019/1020 can fill both roles.
Comparison
| Point | GPSR Responsible Person | CE Authorised Representative |
|---|---|---|
| Legal basis | Regulation (EU) 2023/988, Article 16, and Regulation (EU) 2019/1020, Article 4 | The product’s harmonisation legislation (framework of Decision 768/2008/EC, Article R6) |
| Products concerned | Consumer products covered by the GPSR, sold online or offline | Products subject to CE marking (toys, electronics, machinery, PPE, medical devices…) |
| Who can take the role | An EU-established manufacturer or importer, an authorised representative, or a fulfilment service provider | A natural or legal person established in the EU, appointed by the manufacturer |
| Written mandate | Required when the role is given to an authorised representative | Always required; it sets the delegated tasks |
| Main tasks | Verify documentation, cooperate with authorities, report risks, appear on the product or parcel | Keep the EU declaration of conformity and technical documentation available, answer authorities, cooperate on corrective action |
| What the role does not cover | The product’s intrinsic safety remains the manufacturer’s responsibility | Conformity assessment and drawing up the technical documentation remain with the manufacturer |
How to tell what you need
- You are established outside the EU and sell a consumer product to EU customers with no EU-established importer: you need a responsible economic operator established in the EU (GPSR Article 16).
- Your product carries CE marking: appoint a CE authorised representative by written mandate. Some legislation makes this mandatory for non-EU manufacturers (medical devices, for example).
- Your product carries CE marking and is sold to consumers: a single EU-established authorised representative can cover both roles if its mandate includes the tasks in Article 4 of Regulation (EU) 2019/1020.
One entity for both roles?
Yes, this is common: Regulation (EU) 2019/1020 recognises the authorised representative as the responsible operator when a written mandate gives it the Article 4 tasks. Check that the mandate lists the products, models and legislation covered, and that its name and addresses appear on the product or packaging.
What about Great Britain?
An EU-established responsible person or authorised representative does not cover sales in Great Britain, which fall under UK product safety law. Check the UK requirements for your product separately.
Frequently asked questions
Is a GPSR Responsible Person the same as a CE Authorised Representative?
No. The GPSR Responsible Person is an EU-presence requirement for consumer products; the CE Authorised Representative is appointed by mandate under harmonisation legislation. The same EU-established representative can, however, fill both roles if its mandate says so.
Can a non-EU manufacturer sell on Amazon or Etsy without an EU-established operator?
Not for a product covered by the GPSR: the online offer must show the manufacturer and, if it is established outside the EU, the EU responsible person (Article 19), and the product cannot be placed on the market without a responsible economic operator established in the Union (Article 16).
Does a CE Authorised Representative carry out the conformity assessment?
No. Conformity assessment, the technical documentation and the EU declaration of conformity remain the manufacturer’s obligations; the authorised representative performs the tasks set by the mandate, such as keeping documents available to authorities.
Reference texts
- Regulation (EU) 2023/988 on general product safety
- Regulation (EU) 2019/1020 on market surveillance
- Decision No 768/2008/EC — common framework for the marketing of products
- The Blue Guide 2022 on the implementation of EU product rules
- Regulation (EU) 2017/745 on medical devices
Sources checked on 30 September 2026.