EU GPSR Responsible Person for non-EU manufacturers

The GPSR is Regulation (EU) 2023/988 on general product safety. Applicable since 13 December 2024, it strengthens safety, traceability, and information obligations for consumer products sold in the European Union, including through distance selling. The official text is available on [EUR-Lex](https://eur-lex.europa.eu/eli/reg/2023/988/oj).

No. The Regulation contains exclusions, and certain categories are governed by specific sector legislation. For products subject to harmonised rules, the GPSR may nevertheless supplement matters not already covered by those rules. The assessment must therefore begin with the product’s nature, intended use, and reasonably foreseeable users, not merely its commercial name.

A product covered by the GPSR may not be placed on the Union market unless an EU-established economic operator is responsible for the tasks referred to in Article 16. For a manufacturer located outside the EU, that operator may be the importer, an authorised representative holding a written mandate, or, in certain circumstances, a fulfilment service provider. The role actually performed in the supply chain must be identified; merely adding a European address to the label is not sufficient.

Depending on the supply chain, it can be the EU-established manufacturer, the importer, an authorised representative appointed in writing, or a fulfilment service provider where no other relevant operator is established in the Union. A marketplace, warehouse, or carrier does not automatically become the responsible person simply because it is involved in the sale or delivery.

The responsible person performs the regulatory tasks associated with its role and the product: required documentary checks, keeping relevant evidence available to authorities, cooperating with market surveillance, and supporting corrective action where necessary. The GPSR also provides for regular checks proportionate to the risks. The details must be defined in the mandate and cannot be reduced to displaying a name and address.

Article 19 requires the manufacturer’s name and postal and electronic contact details to be clearly visible, followed by those of the responsible person when the manufacturer is not established in the Union. The offer must also identify the product, including through an image and its type or another identifier, and display the required warnings or safety information in a language that consumers in the target market can easily understand.

The name or registered business name and the postal and electronic contact details of the responsible economic operator must appear on the product, its packaging, the parcel, or an accompanying document, as permitted by the Regulation. For online sales, this information must also be visible in the offer; placing it only inside the parcel after purchase is therefore not enough to inform the customer on the product page.

No. The manufacturer remains responsible for product safety, risk analysis, traceability, and its own statutory duties. Importers and distributors also retain their obligations when they perform those roles. The responsible person provides an EU-established contact for defined tasks; it does not remove the responsibilities of the other parties.

Only when the scope has been reviewed and expressly accepted. Each product family must be identifiable and supported by information on the manufacturer, risks, traceability, warnings, and target markets. A new reference, a substantial modification, or a change of manufacturer must be reported before the product can be considered covered.

A proper process begins with an eligibility and product-scope review, followed by document collection and resolution of identified gaps. The engagement becomes effective only after express acceptance, signature of the mandate, and completion of the conditions stated in the offer. Sending a request, creating a SaaS account, or making an isolated payment must not be interpreted as automatic coverage of products that have not been approved.