The EU Responsible Person under the GPSR

Since 13 December 2024, every consumer product reaching European buyers carries a name behind it: a party established in the Union who answers for that product's safety. The General Product Safety Regulation made that a condition of market access, and through 2026 enforcement has caught up with the text. Customs authorities check labelling at the border. Marketplaces verify the details before a listing reaches EU buyers, and surveillance authorities increasingly ask for the underlying documentation directly.

What the regulation asks

The GPSR has applied since 13 December 2024 and covers every consumer product reaching the European market, whether through a physical shop, a webshop or a marketplace. It reaches manufacturers, importers, distributors, fulfilment service providers and the marketplaces themselves.

At its centre sits one structural requirement: for each product placed on the EU market there is a party established in the Union who answers for it. That party is the manufacturer where the manufacturer sits inside the EU, the importer where goods enter through one, or an authorised representative appointed for the purpose. Their name and contact details appear on the product or its packaging and in the online listing.

Article 16 gives the role real content. The responsible person verifies that the technical documentation and risk assessment exist and remain current, holds that documentation available for ten years, serves as the point of contact for market surveillance authorities, and cooperates where corrective action becomes necessary. Recall remedies offer the consumer a choice of at least two options among repair, replacement and refund.

Who can hold the role

A seller established outside the European Union has three ways to satisfy the requirement:

• An EU manufacturer. Where production takes place inside the Union, the manufacturer holds the role by definition.
• An EU importer. Where goods are sold to a European distributor who brings them in, that importer takes the role.
• An authorised representative established in the EU. Appointed by written mandate, holding the technical documentation and acting as the contact point for authorities.

A company established outside the Union holds the role itself once it has an establishment inside it. That is the route many growing brands choose, because it keeps the technical files, the customer relationship and the compliance position inside the group.

Where the requirement sits alongside others

The GPSR works together with the Market Surveillance Regulation, whose Article 4 has required an economic operator established in the Union for CE-marked products since 2021. The Packaging Regulation adds an authorised representative for extended producer responsibility, appointed per Member State. Sellers meeting all three find that a single Dutch entity resolves them together, which is why the decision is worth taking once, deliberately.

Why the Netherlands

Three practical reasons. The Netherlands offers an English-speaking commercial environment and a business register that European buyers and marketplaces recognise immediately. Rotterdam and Schiphol handle the goods flows, and Dutch fulfilment capacity is dense. And a Dutch BV applies for the Article 23 licence, which moves import VAT to the periodic VAT return where it is declared and deducted in the same filing — a working-capital advantage on every consignment. See our guide to fiscal representation and Article 23.

Guides by market

• United Kingdom sellers — selling into the EU after Brexit
• United States sellers — reaching European consumers
• Marketplace sellers — Amazon, eBay and Etsy compliance
• Representative or your own entity — how to choose

Frequently asked questions

What is an EU responsible person under the GPSR?

For every consumer product placed on the EU market there is a party established in the Union who answers for its compliance. That party is the manufacturer where it sits inside the EU, the importer where goods enter through one, or an authorised representative appointed by written mandate. Their name and contact details appear on the product or its packaging and in the online listing.

Since when does the GPSR apply?

Regulation (EU) 2023/988 has applied since 13 December 2024, replacing the General Product Safety Directive 2001/95/EC. Through 2026 enforcement has broadened, with customs checks at the border, marketplace verification of listing data and direct documentation requests from market surveillance authorities.

What does the responsible person actually do?

Article 16 sets out the duties: verifying that the technical documentation and risk assessment exist and stay current, holding that documentation available for ten years, acting as the contact point for market surveillance authorities, and cooperating where corrective action becomes necessary.

Can a company outside the EU be its own responsible person?

The role belongs to a party established in the Union. A company outside the EU satisfies the requirement by appointing an authorised representative, by selling through an EU importer, or by establishing its own EU entity such as a Dutch BV that acts as importer and holds the role within the group.

Which products does the GPSR cover?

Consumer products generally, sold through physical shops, webshops or marketplaces. The regulation reaches manufacturers, importers, distributors, fulfilment service providers and online marketplaces alike.