Amazon GPSR for Resellers vs Brand Owners: Who Provides the Responsible Person?

Amazon's “brand owner” vs the GPSR “manufacturer”

Amazon separates sellers into brand owners and resellers. GPSR (Regulation (EU) 2023/988) uses economic operator roles instead. The two map roughly, but not exactly:

• Manufacturer: makes a product, or has it designed or made, and markets it under its own name or trademark (Article 3, point 8). Usually the brand owner; for OEM goods it is the brand owner, not the factory.
• Distributor: anyone in the supply chain other than the manufacturer or importer who makes a product available on the EU market (point 11). Resellers on an existing listing usually fall here, and the definition does not require EU establishment.
• Importer: established in the EU and first places a product from outside the EU on the EU market (point 10). A reseller that is an EU company importing the goods itself is an importer, with heavier duties.

The same seller can hold different roles for different products: manufacturer for its own brand, distributor for another brand it resells (section 1.1 of the Commission's business guidelines C/2025/6233; recital 46). See economic operator roles. This guide covers GPSR only, not brand authorisation or intellectual property questions around reselling.

Brand owner vs reseller: GPSR duties side by side

The information shown in the listing is the same for both. The difference is who creates it: the brand owner produces it, the reseller checks it and shows it accurately. Full distributor duties: GPSR distributor obligations.

What Amazon has said publicly

Amazon's GPSR implementation announcement on its seller forums lists separate expectations (summarised here):

• Brand owners: verify product compliance, enrol in Amazon Brand Registry, appoint a responsible person, provide manufacturer information and display the necessary details on product pages.
• Resellers: verify compliance, provide responsible person and manufacturer information, and display product pictures and safety information.

The announcement adds that non-compliant listings risk removal and ineligibility for flash sales, and states that it is guidance, not legal advice. Information is submitted through compliance pages in Seller Central; page names and flows change, so follow the current instructions for your marketplace. If a listing is already blocked, see Amazon GPSR listing deactivated.

For a reseller, the key point is that the “responsible person and manufacturer information” Amazon asks for is the real manufacturer and responsible person of the product, as arranged by the brand, and it must match the labels on the units you hold. Do not copy what another seller entered on the same listing: their stock may come through a different importer, and section 4.2 of the Commission's Article 4 guidelines (2021/C 100/01) says each importer is responsible only for the units it placed on the market.

What a reseller must check before selling

Article 12(1) requires a check of the physical product, not just the brand's photos:

1. a type, batch or serial number on the product (Article 9(5));
2. the manufacturer's name, registered trade name or trade mark, postal address and a directly usable electronic address (Article 9(6));
3. where there is an EU importer, its name and address, not hidden by an added sticker (Article 11(3));
4. instructions and safety information in a language consumers in the selling country easily understand (Article 9(7)), checked separately for Germany, France, Italy and each other store you sell in;
5. the EU responsible person's name, postal and electronic address on the product, packaging, parcel or an accompanying document (Article 16(3)).

Ask the brand or your supplier in writing for the full manufacturer and responsible person details, instructions and warnings in each language, product images and a contact for safety issues. File these with photos of your check, and keep supplier and customer records for six years (Article 15(3) and (5)). If anything is missing, do not list the product yet (Article 12(3)). Label fields are explained in GPSR label requirements.

What if the brand owner has no EU responsible person?

This is the most common reseller problem. Article 16(1) bars placing a product on the market without an EU responsible person, and an authorised representative must be mandated in writing by the manufacturer (Article 3, point 9; Article 10(1)). A reseller therefore cannot sign up an EU Rep itself and enter its address as the brand's responsible person. Section 2.2 of the Commission's Article 4 guidelines speaks directly to non-EU operators planning to sell online: check with the manufacturer whether it has appointed an authorised representative; if not, find one in cooperation with the manufacturer and make sure the manufacturer authorises it.

Lawful routes:

• Get the brand to mandate an authorised representative. Send the brand Amazon's requirement and the legal basis, and ask it to sign a written mandate and put the details on the product or packaging. See the authorised representative mandate.
• You are an EU company importing the goods yourself. You are then the importer, and where the manufacturer is outside the EU and has no authorised representative you are the responsible person (Regulation 2019/1020, Article 4(2)(b)), with all Article 11 and 16 duties, including keeping a copy of the technical file for 10 years. You will need the brand's technical documentation.
• Buy from an EU importer. That importer is the responsible person for the units it imported; check its details are on the goods.
• None of these works: do not sell the product in EU stores. Invented or borrowed addresses are not compliance.

Do not count on Amazon as a fallback; its announcement asks sellers to provide responsible person details. For fulfilment questions see Amazon FBA vs FBM.

When a reseller becomes the manufacturer

Article 13(1): anyone placing a product on the market under their own name or trademark is deemed the manufacturer. A reseller that puts its own brand on unbranded goods, repackages them under its own trademark or creates a new listing under its own brand is no longer a distributor. It takes on all Article 9 duties and, if outside the EU, must arrange its own EU responsible person.

Article 13(2) and (3): a substantial modification that affects safety and was not foreseen in the original risk assessment (for example a different power supply or intended use) makes the modifier the manufacturer for that part or the whole product. Translating instructions while still selling under the original brand generally leaves you a distributor according to the Commission's guidelines, but the brand should approve the translation.