EU Responsible Person

EU Responsible Person under GPSR: Who It Is and When You Must Appoint One

Q: Can I be my own responsible person with an EU VAT number?

The law requires the operator to be established in the EU. A VAT or EORI registration alone generally does not establish your company in the EU. An EU subsidiary that imports in its own name can act as importer; ask a local lawyer whether your set-up counts as establishment.

Last checked against the official texts: 6 November 2026 · Based on Regulation (EU) 2023/988

Short answer

Under GPSR Article 16 and Article 4 of Regulation (EU) 2019/1020, a consumer product may only be placed on the EU market if an economic operator established in the EU is responsible for it: an EU manufacturer, an importer, an authorised representative or a fulfilment service provider. A non-EU brand with no EU importer will in practice need to appoint an authorised representative in writing. That operator's name, postal address and electronic address must appear on the product, packaging, parcel or an accompanying document, and in online listings.

Key points

No EU-established responsible person, no placing on the EU market (GPSR Article 16(1)).
Only four types qualify: EU manufacturer, importer, authorised representative with a written mandate, EU fulfilment service provider.
If you ship directly from outside the EU to consumers, only an authorised representative can fill the role.
The responsible person verifies documentation, answers authorities, reports risks and regularly checks products and labels.
Medical-device EC REPs, cosmetics Responsible Persons and UK Responsible Persons are separate roles under other laws.

What the law actually requires: GPSR Article 16 and Article 4 of Regulation 2019/1020

Sellers say “EU Rep”, “EC-REP” or (in Chinese) 欧代, but the regulation uses none of those words. GPSR (Regulation (EU) 2023/988) Article 16(1) says a product covered by the regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020 for that product. The Commission's 2025 business guidelines (C/2025/6233) call this operator the “responsible person”. This article cites Commission guidance in several places; guidance interprets the regulation but is not the law itself, so the regulation text prevails.

There are actually two legal routes to the same requirement:

General consumer products with no specific EU safety legislation (furniture, homeware, stationery, sports goods, accessories and so on): GPSR Article 16 applies, from 13 December 2024.
CE-marked products under the laws listed in Article 4(5) of Regulation 2019/1020 (toys, low-voltage electrical equipment, radio equipment, EMC, RoHS, PPE, machinery and others): Article 4 of Regulation 2019/1020 has applied directly since 16 July 2021. GPSR Article 2(1) switches off Chapter III Section 1 (which contains Article 16) for products subject to Union harmonisation legislation, so for these products the legal basis is Article 4, with essentially the same result.

For most sellers on Amazon EU, Temu, TikTok Shop or their own websites the practical message is identical: someone inside the EU must be reachable by authorities and able to produce compliance documents. Cosmetics and medical devices have their own regimes (see below).

The four types of responsible person

Article 4(2) of Regulation 2019/1020, which GPSR Article 16(1) applies, lists four options. The order matters: the fourth only applies when none of the first three exists.

Type	Definition (GPSR Article 3)	When it is the responsible person	Relevance for non-EU sellers
EU manufacturer	Makes or has a product designed or made and markets it under its own name or trademark (point 8)	The manufacturer is established in the EU	Only if your brand-owning company is itself in the EU
Importer	Established in the EU and places a product from a third country on the EU market (point 10)	The manufacturer is outside the EU	An EU wholesaler, or your own EU subsidiary importing in its own name
Authorised representative	Established in the EU with a written mandate from the manufacturer to act on its behalf for specified tasks (point 9)	The mandate designates it to perform the Article 4(3) tasks	The most common route, sold as “EU Responsible Person services”
Fulfilment service provider	Offers at least two of warehousing, packaging, addressing and dispatching without owning the goods; postal, parcel and freight services excluded (point 12)	Only where none of the above is established in the EU, and only for products it handles	A fallback, not something to rely on (see the last section)

The Commission's 2021 guidelines on Article 4 (2021/C 100/01) start from the mandate: if the manufacturer has mandated an authorised representative for the Article 4 tasks, that representative is the responsible person. Otherwise it depends on the supply chain.

When a non-EU seller must appoint one

Two questions decide it: is the manufacturer (brand owner) established in the EU, and how do the goods enter the EU? Based on the steps in section 2.2 of the Commission's Article 4 guidelines:

Scenario	Who can be the responsible person	What to do
Non-EU brand shipping parcels directly to EU consumers (merchant-fulfilled, cross-border direct mail)	No importer and no EU warehouse. The guidelines say only an authorised representative can act; without one the product may not be offered to EU end users	Appoint an authorised representative in writing
Non-EU brand stocking Amazon FBA or a third-party EU warehouse	In theory the fulfilment service provider is the fallback if there is no importer or authorised representative	Appoint an authorised representative anyway (see the Amazon section)
Your own EU subsidiary imports and sells in its own name	The subsidiary, as importer	Make sure it is genuinely established, can hold documents, and that its details are on the product as GPSR Article 11(3) requires
You resell another brand's products	The brand owner should arrange it	Ask your supplier for manufacturer and responsible person details before listing

Two common misunderstandings. First, the law requires the operator to be established in the Union. Holding an EU VAT number or an EORI number does not, in general, mean your company is established in the EU; take local legal advice before relying on that to act as importer. Second, one responsible person established in any member state is enough for the whole EU. The Commission guidelines confirm that authorities can contact a responsible person located in another member state.

Not sure which scenario you are in? Try the 3-step compliance check.

What the responsible person has to do

The tasks come from Article 4(3) of Regulation 2019/1020 (with “Union harmonisation legislation” read as the GPSR, per Article 16(1)), plus GPSR Articles 16(2) and 20(4):

Verify and secure documentation: check that the manufacturer has drawn up the technical documentation (GPSR Article 9(2)) and ensure it can be given to market surveillance authorities on request. For CE products, also verify and keep the EU declaration of conformity.
Answer reasoned requests: give the authority all information and documentation needed to demonstrate compliance, in a language the authority can easily understand.
Report risks: inform the market surveillance authorities when it has reason to believe a product presents a risk.
Cooperate on corrective action: make sure immediate corrective action (fix, withdrawal, recall) is taken, or the risk is mitigated if that is not possible.
Regular checks (Article 16(2)): where appropriate to the risks, regularly check that the product matches the technical documentation and meets Article 9(5), (6) and (7) (identification number, manufacturer details, instructions and safety information), and give documented evidence of those checks on request.
Accidents (Article 20(4)): where the manufacturer is outside the EU, a responsible person who knows of an accident must ensure it is notified through the Safety Business Gateway.

The responsible person does not take over the manufacturer's responsibility. The manufacturer still owns product safety, the risk analysis and the technical file. The Commission's Blue Guide 2022 notes that an authorised representative's tasks are administrative: it cannot draw up the technical documentation for you or modify the product on its own initiative. If the manufacturer stops cooperating, the Article 4 guidelines say an authorised representative may end the relationship, which leaves your products without a responsible person.

For contracts and what providers will ask for, see how to choose an EU Responsible Person; for the file itself, see GPSR technical documentation.

Where the name and address must appear

GPSR Article 16(3) requires the responsible person's name, registered trade name or registered trade mark, and contact details including postal and electronic address on the product, its packaging, the parcel or an accompanying document. Article 4(4) of Regulation 2019/1020 sets a similar rule for CE products.

Information	Legal basis	Where
Manufacturer name, trade name or mark, postal and electronic address	GPSR Article 9(6)	On the product; if not possible, packaging or accompanying document (not the parcel)
Responsible person name, trade name or mark, postal and electronic address	GPSR Article 16(3)	Product, packaging, parcel or accompanying document
Online offer: manufacturer details and, if the manufacturer is outside the EU, the responsible person's name, postal and electronic address	GPSR Article 19	The product listing, “clearly and visibly”

Practical points from the Commission guidance: an “electronic address” can be an email address or a web page that allows direct contact; a bare website is not enough, and a web address can supplement but not replace a postal address. Labels such as “Represented by” or “Imported by” are not mandatory, but the information must not mislead authorities, and these English terms need no translation. For CE products, the Article 4 guidelines add that the details must already be on the goods when they are released for free circulation at customs, so add them before shipping.

QR codes and web links are only a supplement: GPSR Article 21 lets operators make this information available additionally in digital form, without prejudice to Article 16(3) and the other on-product rules. A scan-to-view page does not replace the responsible person's details on the product or packaging. See GPSR label requirements for layouts.

EC REP, cosmetics Responsible Person, UK Responsible Person: not the same thing

Many providers market GPSR services as “EC-REP” or “EU REP”, but those labels come from other regimes with different rules:

Role	Legal basis	How it differs from the GPSR responsible person
Medical device authorised representative (the “EC REP” symbol on labels)	Regulation (EU) 2017/745 (MDR), Article 11	Mandatory for non-EU manufacturers, who must designate a sole authorised representative, which must have a person responsible for regulatory compliance permanently available (Article 15(6)). The EC REP symbol comes from the medical-device symbols standard ISO 15223-1. A GPSR mandate does not replace an MDR mandate.
Cosmetics Responsible Person	Regulation (EC) No 1223/2009, Article 4	Every cosmetic product needs one in the EU; for imports it is the importer or a person designated by written mandate who accepts in writing. It keeps the product information file for ten years after the last batch is placed on the market (Article 11). See the cosmetics white paper.
UK Responsible Person	UK domestic law	EU GPSR does not apply in Great Britain, but UK rules require a UK-based responsible person for some categories (for example cosmetics). Northern Ireland applies the EU GPSR; UK government guidance says the responsible operator there can be established in the EU or in Northern Ireland.

If you sell in both the EU and the UK, or sell both general goods and cosmetics, check each role separately. One company can hold several roles, but it needs the matching mandate and capability for each, not a single address “for everything”.

Does Amazon FBA count as a fulfilment service provider?

By definition, a business that offers at least two of warehousing, packaging, addressing and dispatching without owning the goods is a fulfilment service provider. The Commission's GPSR guidelines give the example of an online marketplace that also provides warehousing and packaging for some products: for those products it is a fulfilment service provider. FBA fits that description.

That does not mean FBA is your EU Responsible Person:

A fulfilment service provider is only the fallback where there is no EU manufacturer, importer or authorised representative (Article 4(2)(d) of Regulation 2019/1020), and the Commission guidelines say it first needs to receive the means to carry out the tasks from its client or the manufacturer.
Amazon's public GPSR announcement on its Seller Central forums says a Responsible Person established in the EU is mandatory for non-food products, that brand owners must appoint one, that resellers must provide Responsible Person and manufacturer information, and that non-compliant listings risk removal. We found no public statement from Amazon that it will act as the responsible person for FBA products.
Under that announcement, sellers submit the responsible person details in Seller Central for display on the product page. The legal requirement to show them on the physical goods (Article 16(3)) is not removed by using FBA.

The practical route is to mandate an authorised representative that can actually handle authority requests, enter its details in Seller Central and print them on the product or packaging. Seller Central wording and workflows change, so follow what your account currently shows. If listings are already blocked, see Amazon GPSR listing deactivated.

EU Responsible Person checklist

Identify the manufacturer of each brand you sell and whether it is established in the EU.
Map how goods reach EU consumers: direct parcels, FBA or EU warehouse, or an EU importer.
If there is no EU manufacturer or importer, sign a written mandate with an EU authorised representative covering the Article 4(3) tasks.
Give the representative your technical documentation, test reports and label files.
Print the representative's name, postal address and electronic address on the product, packaging, parcel or accompanying document.
Enter manufacturer and responsible person details in every EU listing (Amazon, Temu, TikTok Shop, own shop).
Check cosmetics, medical devices and the UK market separately.
Review the mandate, product list and labels at least once a year.

Common mistakes

Assuming FBA or an EU warehouse is your representative
A fulfilment service provider is only the fallback where there is no EU manufacturer, importer or authorised representative (Regulation 2019/1020 Article 4(2)(d)), and it first needs documents and cooperation from you. Amazon's public announcement asks sellers to supply responsible person details themselves. Do not treat the warehouse as your EU Responsible Person.
Details in the listing but not on the product
Article 19 requires the details in the online offer; Article 16(3) separately requires the name, postal address and electronic address on the product, packaging, parcel or an accompanying document. Doing only one is not enough, and a QR code does not replace the physical information (Article 21).
Using a medical-device or cosmetics representative as your GPSR representative
MDR authorised representatives, cosmetics Responsible Persons and UK Responsible Persons each have their own legal basis and scope. Using one company is fine, but you need a written mandate that covers the relevant products and tasks, not one address assumed to work for everything.

Frequently asked questions

Does every non-EU seller need an EU Responsible Person?

If you sell products covered by the GPSR or Article 4 of Regulation 2019/1020 to EU consumers, an EU-established responsible person must exist for each product. If the brand owner is outside the EU and there is no EU importer, that normally means appointing an authorised representative. For direct shipments from outside the EU, it is the only option.

Can I be my own responsible person with an EU VAT number?

The law requires the operator to be established in the EU. A VAT or EORI registration alone generally does not establish your company in the EU. An EU subsidiary that imports in its own name can act as importer; ask a local lawyer whether your set-up counts as establishment.

Do I need a different responsible person for each EU country?

No. GPSR Article 16 requires one economic operator established in the Union, and authorities in any member state can contact it. Check that it can supply documents in a language the requesting authority understands, or arrange translation.

Is it enough to show the responsible person in the listing only?

No. Article 16(3) requires the details on the physical goods (product, packaging, parcel or accompanying document), and Article 19 separately requires them in the online offer. You need both.

Can my medical-device EC REP also be my GPSR representative?

Not automatically. An MDR authorised representative acts under MDR Article 11 with its own scope and qualification rules. If the same company is to cover your general consumer products, sign a separate written mandate covering those products and the Article 4(3) tasks.

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.