EU Responsible Person

GPSR Authorised Representative Mandate: What the Written Mandate Must Contain (Clause Checklist)

Last checked against the official texts: 7 November 2026 · Based on Regulation (EU) 2023/988

Short answer

The mandate is the written appointment of an EU authorised representative by the manufacturer (GPSR Article 10(1)). It must allow the representative to perform at least the four tasks in Article 10(2), and if the representative is also to be your EU Responsible Person it must expressly designate it for the tasks in Article 4(3) of Regulation (EU) 2019/1020. There is no official template: product scope, documents, response times, recall roles, termination and liability are for the parties to write down, and a lawyer should review the text before you sign.

Key points

The law only requires a written mandate: no set form, language or notarisation. Authorities can ask the representative for a copy.
The four Article 10(2) tasks are not enough on their own: to act as responsible person, the mandate must expressly include the Article 4(3) tasks of Regulation 2019/1020.
For CE products such as toys and electrical equipment, the sector law (Toy Safety Directive Art. 5, LVD Art. 7, EMC Art. 8, RED Art. 11) and Regulation 2019/1020 set the minimum; GPSR Article 10 does not apply.
Product scope, document access, response times and recall roles are the clauses most often left vague.
The law has no specific rule on products still carrying a former representative's details, so agree the exit arrangements in advance.

What the mandate is in law: two levels

GPSR (Regulation (EU) 2023/988) Article 3(9) defines an authorised representative as a natural or legal person established in the Union who has received a written mandate from a manufacturer to act on its behalf in relation to specified tasks under the Regulation. Article 10(1) only requires the mandate to be written. It sets no format, language, notarisation or term, so its quality depends on what you and the representative write.

Sellers need to distinguish two levels:

Authorised representative only: performs the Article 10(2) tasks. The law allows this, but the representative is then not necessarily your EU Responsible Person.
Authorised representative acting as responsible person: GPSR Article 16(1) requires, for every product placed on the market, an economic operator established in the Union responsible for the tasks in Article 4(3) of Regulation 2019/1020. Under Article 4(2)(c), an authorised representative fills that role only if its written mandate designates it to perform the Article 4(3) tasks. Non-EU sellers without an EU importer almost always need this level.

The Commission's GPSR business guidelines (C/2025/6233) add that a representative designated as responsible person also takes on the Article 16(2) checks and the Article 20(4) accident duty. (Guidelines interpret the law; the regulation text prevails.) See who the EU Responsible Person is and economic operator roles.

The legal minimum depends on your product

Under GPSR Article 2(1), for products subject to Union harmonisation legislation (typically CE-marked products), Chapter III Section 1 of the GPSR (Articles 9 to 18, including Articles 10 and 16) does not apply. For those products the mandate follows the sector law and Regulation 2019/1020, while GPSR Articles 19 and 20 and the recall rules in Articles 35 to 37 still apply.

Product	Minimum mandate content	Legal basis
General consumer products with no specific safety law (home goods, accessories, kitchenware, sports goods)	(1) on a reasoned request, give authorities the information and documents showing the product is safe; (2) tell the manufacturer if it believes a product is dangerous; (3) notify risk-elimination action via the Safety Business Gateway if the manufacturer has not; (4) cooperate on such action	GPSR Art. 10(2)(a)–(d)
Acting as responsible person (GPSR and CE products)	Verify the technical documentation (and, for CE products, the declaration of conformity) has been drawn up and can be provided; supply information and documents on request; inform authorities of risks; cooperate and make sure corrective action is taken	Reg. 2019/1020 Art. 4(2)(c) and 4(3); Art. 5(1)
Toys (current law)	Keep the EC declaration of conformity and technical documentation for 10 years; supply documents on request; cooperate on eliminating risks	Directive 2009/48/EC Art. 5(3)
Toys (from 1 August 2030)	Adds the digital product passport and Safety Business Gateway notifications; a non-EU manufacturer's mandate must include the Article 4(3) tasks	Regulation (EU) 2025/2509 Art. 8
Electrical, electronic and radio equipment	Keep the EU declaration of conformity and technical documentation for 10 years; supply documents on request; cooperate on eliminating risks	LVD 2014/35/EU Art. 7; EMC 2014/30/EU Art. 8; RED 2014/53/EU Art. 11

Two points are often missed. First, each of these sector laws excludes from the mandate the manufacturer's duty to ensure conformity and to draw up the technical documentation; the Commission's Blue Guide 2022 adds that delegable tasks are administrative and a representative cannot modify the product on its own initiative. GPSR Article 10 has no such express exclusion, but Article 9 puts the risk analysis and technical file on the manufacturer: a representative holding your file is not writing it. Second, Article 5(3) of Regulation 2019/1020 requires the representative to have the appropriate means to fulfil its tasks, and the GPSR guidelines expect practical capacity and suitable language skills. See also the toys and electronics white papers.

Clause checklist: clause, why it matters, legal basis

Review a draft clause by clause; “Contract” means no article applies.

Clause	Why it matters	Related provisions
Parties: both legal names; the representative's country and number of registration, postal and electronic address	The representative must be established in the EU; these details go on products and listings	GPSR Art. 3(9), 16(3), 19(b)
Designation: expressly designates it for the Article 4(3) tasks (plus the sector-law article for CE products)	Without this sentence it may be a representative but not your responsible person	Reg. 2019/1020 Art. 4(2)(c), 5(1)
Product scope: brands, models, product types, an annex of ASINs/SKUs, and how new products are added	The tasks apply to “products covered by their mandate”; a product outside it has no responsible person	GPSR Art. 10(2)(c)–(d), 16(1)
Statutory tasks	The mandate must allow “at least” these tasks	GPSR Art. 10(2); Reg. 2019/1020 Art. 4(3); sector law
Regular checks: frequency, method (samples, photos, label files), who keeps the records	The responsible person must check the product against the technical file, identifiers, manufacturer details and instructions, with documented evidence	GPSR Art. 16(2); Art. 9(5)–(7)
Document delivery and access: which files, where they are held, how fast you supply missing ones	Documents must be producible when an authority asks	GPSR Art. 9(3); Reg. 2019/1020 Art. 4(3)(a)–(b)
Response times: how fast the representative tells you, how fast you supply documents or answers	The law sets no single deadline; the authority sets it in its request	GPSR Art. 10(2)(a); Reg. 2019/1020 Art. 4(3)(b)
Two-way safety information	The representative must tell you if it believes a product is dangerous; you must keep responsible persons informed of safety issues you identify	GPSR Art. 10(2)(b), 9(10); Reg. 2019/1020 Art. 4(3)(c)
Accidents: how fast you report to the representative, who files in the Safety Business Gateway	If the manufacturer is outside the EU, a responsible person who knows of an accident must ensure it is notified	GPSR Art. 20(1), 20(4)
Corrective action and recalls: withdrawal, recall notice, remedies, who pays	Recall notices and remedies have mandatory content, and the representative must cooperate with authorities	GPSR Art. 10(2)(d), 35–37; Reg. 2019/1020 Art. 4(3)(d)
Use of name and address: on which products, packaging and listings, exact wording, stopping after termination	Responsible person details must appear on the product, packaging, parcel or accompanying document and in online offers	GPSR Art. 16(3), 19
Copy of the mandate and its language	Authorities can request a copy; under Reg. 2019/1020 it must be in an EU language the authority determines	GPSR Art. 10(2); Reg. 2019/1020 Art. 5(2)
Term, termination and after-termination arrangements	Old details stay on the market after the relationship ends (see below)	Contract; GPSR Art. 16(1), 16(3)
Fees, liability, insurance, confidentiality, governing law	Not regulated; commercial negotiation	Contract

To compare providers, see how to choose an EU Responsible Person.

Documents, response times and recalls

Documents

GPSR Article 9(3) requires the manufacturer to keep the technical documentation available to authorities for 10 years after the product is placed on the market; appointing a representative does not shift that duty. The responsible person's task is to verify that the documentation exists and ensure it can be made available on request (Regulation 2019/1020 Article 4(3)(a)). The Commission's Article 4 guidelines accept either the representative holding the file, or checking that it exists and obtaining the manufacturer's assurance that it will be supplied on request. For CE products, the sector laws require the mandate to let the representative keep the declaration of conformity and technical documentation for 10 years. List the documents (technical file, risk analysis, test reports, declaration of conformity, label and instruction files), the delivery method, your deadline for missing items, and what happens to the file at the end. See GPSR technical documentation.

Response times

There is no statutory deadline for answering an authority. The Article 4 guidelines say the responsible person should act within a reasonable time or any deadline the authority sets; the Blue Guide notes that a shorter deadline is possible where a serious risk justifies urgency. Instead of “as soon as possible”, write working days: how fast the representative forwards a request, how fast you supply documents, and who arranges and pays for translation (Article 10(2)(a)).

Accidents and recalls

Under Article 20(4), where the manufacturer is outside the EU, a responsible person who knows of an accident must ensure it is notified via the Safety Business Gateway. Article 35 requires economic operators, according to their obligations (including Article 10), to notify affected consumers; Article 36 sets the content of a recall notice and Article 37 the remedies. Say who files in the Safety Business Gateway, drafts the recall notice, contacts marketplaces and consumers, and pays for remedies. See accidents, recalls and Safety Gate.

Termination and switching: products already on the market

We found no specific provision in the GPSR, Regulation 2019/1020 or the Commission guidelines on products that carry a former representative's details after the mandate ends. The points below are risks to plan for, not legal rules:

Units already placed on the market had a responsible person when placed, but people will still contact the old representative. Agree that it forwards related requests and complaints for a set period.
Stock not yet placed on the market: Article 16(1) requires a responsible person established in the EU when a product is placed on the market, and Article 16(3) requires its details on the product, packaging, parcel or an accompanying document. The Blue Guide explains that placing on the market is assessed for each individual product, so units placed after termination should in principle carry the new details. When a batch counts as placed depends on your supply chain (for example who owns EU warehouse stock); ask a lawyer if unsure.
Listings: Article 19(b) requires the responsible person's details in online offers, so update every EU marketplace when you switch.
Termination by the representative: the Article 4 guidelines say that if a manufacturer persistently fails to respond, the representative could try to end the relationship, leaving your products without a responsible person.

Agree the notice period, transition forwarding duties, when use of the name stops, and return of documents.

Fees, liability and insurance

The law does not regulate fees and this site gives no price guidance. Common structures are an annual fee per brand, product type or SKU, plus per-case charges for authority requests, translation or recall support. Write down what the annual fee covers, how extras are charged, and any renewal or exit costs.

On liability, the Commission's Article 4 guidelines say the manufacturer remains responsible for compliance and keeps obligations such as product liability, while a responsible person that fails its Article 4 tasks can itself be sanctioned. Penalties are set by each member state (GPSR Article 44; Regulation 2019/1020 Article 41). That is why representatives usually ask for an indemnity. Its scope, liability caps, exclusions, and whether either party must hold insurance are commercial points to negotiate. This article is not legal advice.

Outline and language (not a template to sign)

A common structure, to help you spot gaps in a draft. Have the wording reviewed by a lawyer.

Parties and definitions
Appointment and scope (citing GPSR Article 10, Regulation 2019/1020 Article 4(3) and any applicable sector law)
Products covered (annex of brands, models, ASINs/SKUs and procedure for additions)
Representative's tasks (statutory tasks, regular checks, accident notification)
Manufacturer's obligations (documents, safety issues and accidents, support for checks, fees)
Documentation: delivery, storage and access
Communication, response times and translation
Safety incidents, corrective action and recall roles
Use of name and address
Fees and payment
Liability, indemnity and insurance
Confidentiality and data protection
Term, termination and post-termination arrangements
Governing law and disputes
Language versions and signature

Language: the GPSR does not say what language the mandate must be written in. Article 5(2) of Regulation 2019/1020 requires a representative appointed under that Regulation to provide a copy in an EU language determined by the market surveillance authority. English, or a bilingual version stating which text prevails, is common. The law does not prescribe how the mandate is signed; keep a signed copy ready to produce.

Not sure you need a representative yet? Take the 3-step compliance check.

Mandate review checklist

Confirm the manufacturer (brand owner) signs, and whether your products fall under the GPSR or CE sector law.
Check the mandate expressly designates the representative for the Article 4(3) tasks of Regulation 2019/1020.
Check all four GPSR Article 10(2) tasks (or the sector-law minimum) are included.
Attach a product annex of brands, models and ASINs/SKUs, with a procedure for adding products.
List the documents, delivery method and deadlines, and confirm the 10-year retention arrangements.
Set response times, roles and costs for authority requests, accidents and recalls.
Fix the wording and use of the name and address, and the exit and transition arrangements.
Have a lawyer review it, then keep a signed copy ready for authorities.

Common mistakes

Only the four Article 10 tasks
Article 10(2) is only the minimum for an authorised representative. To make it your EU Responsible Person, the mandate must expressly designate it for the Article 4(3) tasks of Regulation 2019/1020 (Article 4(2)(c)). Look for that sentence first and ask for it if it is missing.
Vague product scope, or new products never added
The tasks apply to products covered by the mandate. “All the seller's products” is hard to prove for a specific model in a dispute, and a new listing outside the annex may have no responsible person. Use an annex of brands, models and ASINs/SKUs with a procedure for additions.
Signing the provider's template unchanged
There is no official template, and a provider's standard text is usually written to protect the provider. Adapt response times, recall costs, liability caps and exit terms to your products and sales channels, and have a lawyer review it before signing.

Frequently asked questions

Does the mandate need to be notarised?

GPSR Article 10(1) and Regulation 2019/1020 only require a written mandate; neither requires notarisation or legalisation. A provider or a specific procedure may ask for more, so check before signing.

Must the mandate be in German or another EU language?

The law does not set the drafting language. Under Article 5(2) of Regulation 2019/1020, a copy must be provided on request in an EU language determined by the authority. English or a bilingual version stating which text prevails is common.

Can one mandate cover several brands and many SKUs?

Nothing in the law prevents it; the mandate must cover specified tasks and products. List every brand, model and ASIN/SKU in an annex and agree how new products are added, so the scope is never in doubt.

I sell toys and Bluetooth headphones. Is a GPSR mandate enough?

Not necessarily. GPSR Article 10 does not apply to CE products, so the mandate must meet the minimum in the Toy Safety Directive Article 5 or the authorised representative articles of the LVD, EMC Directive or RED, and include the Article 4(3) tasks of Regulation 2019/1020. One mandate can cover general products and CE products if it sets out each legal basis.

Can I keep selling stock labelled with my former representative's details?

Neither the law nor the Commission guidance addresses this directly. A product needs a responsible person, with its details on or with the product, when it is placed on the market, so units placed after termination should in principle carry the new details. Which units count as already placed depends on your supply chain; get legal advice and agree a transition period in the contract.

Official sources

This guide explains Regulation (EU) 2023/988 in plain language. It is general information, not legal advice. Requirements can depend on your product, other EU laws and the member state — check the official text and, for your own case, a qualified adviser.