EU Responsible Person

How to Choose an EU Responsible Person: Mandate, Contract Clauses, Costs and Red Flags

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

Short answer

The test of a good EU Responsible Person is whether it can actually produce your compliance documents and deal with an authority when a letter arrives, not just lend you an address. The written mandate must cover at least the tasks in GPSR Article 10(2) and Article 4(3) of Regulation (EU) 2019/1020, and the contract should fix product scope, response times, languages, liability and what happens if you switch provider. A serious provider will always ask for your technical documentation, test reports and label files.

Key points

An authorised representative needs a written mandate from the manufacturer (GPSR Article 10(1)); authorities can ask for a copy.
The mandate must allow at least the four Article 10(2) tasks, and the Article 4(3) tasks if it is to be your responsible person.
One EU-established representative covers all EU member states, but not Great Britain.
Address-only services, no-documents offers and “guaranteed reinstatement” promises are red flags.
Prices vary widely by product count and scope; ask what costs extra before signing.

Know what you are buying

What the market sells as an “EU Rep” service is, legally, usually an authorised representative: a company established in the EU, holding your written mandate as manufacturer, and acting as the responsible person under GPSR Article 16 and Article 4 of Regulation 2019/1020. The other routes are an EU importer or, as a fallback, an EU fulfilment service provider. The differences are explained in who the EU Responsible Person is.

Before you compare providers, settle three things:

Are you the manufacturer? The mandate should be signed by the manufacturer, meaning the business that markets the product under its own name or trademark. If you resell someone else's brand, the brand owner should arrange the representative.
Which law covers your product? General consumer goods fall under GPSR Article 16; CE products such as toys and electrical equipment fall under Article 4 of Regulation 2019/1020; cosmetics and medical devices have their own responsible person or authorised representative regimes that need specific expertise.
Where do you sell? One responsible person established in any member state covers the whole EU, and any national authority can contact it. Great Britain is outside the EU GPSR and has its own rules; Northern Ireland applies the EU GPSR.

The Commission's GPSR business guidelines (C/2025/6233) say an authorised representative should have not only formal authority but also the practical and administrative capacity to carry out its tasks, and probably the language skills to deal with authorities. Article 5(3) of Regulation 2019/1020 also requires it to have the appropriate means to fulfil its tasks. That is the benchmark for any provider. (Commission guidance quoted here interprets the regulation; it is not the law itself, and the regulation text prevails.)

What the written mandate must contain

GPSR Article 10(1) lets a manufacturer appoint an authorised representative by written mandate. Article 10(2) says the representative performs the tasks in the mandate and must give a copy of it to market surveillance authorities on request; Article 5(2) of Regulation 2019/1020 adds that the copy must be in an EU language determined by the authority. As a minimum, check the mandate covers:

Mandate clause	Legal basis	What to check
On a reasoned request, give the authority all information and documents needed to demonstrate product safety, in an official language it understands	GPSR Art. 10(2)(a); Reg. 2019/1020 Art. 4(3)(b)	Who translates and who pays
Inform the manufacturer if it believes a product is dangerous	Art. 10(2)(b)	Channel and timing
Inform authorities via the Safety Business Gateway of action taken to eliminate risks, where the manufacturer has not, or on its instruction	Art. 10(2)(c)	Who logs in and submits
Cooperate with authorities on action to eliminate risks	Art. 10(2)(d); Art. 4(3)(d)	Division of work in a recall or withdrawal
As responsible person: verify the technical documentation exists and can be provided; inform authorities of risks	Reg. 2019/1020 Art. 4(3)(a) and (c); Art. 5(1)	The mandate must expressly designate it for the Article 4(3) tasks
Regular checks of product, identification, manufacturer details and instructions, with documented evidence	GPSR Art. 16(2)	Frequency, and what samples or photos you must supply
Accident notification	GPSR Art. 20(4)	How fast you must tell the representative
List of products covered	Mandates cover “specified tasks” (Art. 3(9)); Art. 10(2)(c) and (d) refer to “products covered by their mandate”	Brands, models, ASINs/SKUs, how new products are added

The GPSR does not prescribe a template. The table combines the legal minimum with common practice; have a lawyer review the wording.

What a genuine provider will ask from you

Because the representative must verify the technical file, run regular checks and answer authorities, a genuine provider will ask for documents. Typically:

Manufacturer details: legal name, business licence, trademark registration, postal and email address.
Product list: brand, model, batch logic, ASIN/SKU, countries and channels.
Technical documentation: description, materials, internal risk analysis, standards applied (GPSR Article 9(2)). See GPSR technical documentation.
Test reports matching the models on sale, and the standards they test against.
CE products: the EU declaration of conformity and any notified body certificate.
Label and packaging files: product label, carton artwork, instructions and warnings in the target languages, product photos.
Complaint channel: the consumer contact required by GPSR Article 9(11) and how you log complaints.

Some providers want everything uploaded; others accept confirmation that the file exists plus your commitment to supply it. The Commission's Article 4 guidelines accept the second approach, provided the representative has checked that the documentation exists and has the manufacturer's assurance it will be supplied on request. For speed, handing over the core file in advance is safer.

Contract clauses to check

Clause	What to look for
Scope	GPSR only, or also Article 4 tasks for CE products; cosmetics or medical devices only with proven expertise
Product list	Priced per brand, product type or SKU; how and at what cost new products are added
Territory	EU-27; Northern Ireland; whether Great Britain needs a separate service
What the fee includes	Handling authority requests, translation, Safety Business Gateway notifications, accident handling; rates for anything extra
Response times	How quickly they notify you of an authority request and reply; how many days you have to supply documents
Languages	Whether they can work with you in your language, and reply in the authority's language or arrange translation
Liability	The representative usually does not take on product liability; the manufacturer stays responsible for safety. Check indemnities, liability caps and professional insurance
Term and notice	Initial term, auto-renewal, notice period, and when the provider may terminate (for example if you fail to provide documents)
Switching provider	What happens to stock already labelled with the old details; whether the old provider keeps forwarding authority requests for a transition period; when new batches switch labels
Confidentiality and data	Protection of technical files and test reports; return or deletion at the end

We found no Commission guidance specifically on products already on the market with a previous representative's details. A cautious approach is a contractual transition period in which the old provider forwards related authority requests, while you update listings and new production quickly. Ask a lawyer about your specific case.

Red flags

Address only, no documents: the responsible person must verify the technical documentation and be able to provide it (Regulation 2019/1020 Article 4(3)(a) and (b)). A provider that never sees your file cannot do that when an authority writes, and the problem comes back to you.
False or empty addresses: the Commission's Article 4 guidelines say that a non-existent address, or no such operator at the address, is treated like missing information, so authorities can require corrective action and impose penalties. Check the company in the national business register and its VAT number in the EU's VIES system.
“One address for all countries”: this is legitimate within the EU. It becomes misleading if the provider claims the same EU address also satisfies Great Britain, or replaces a cosmetics Responsible Person or medical-device authorised representative, without explaining the legal basis.
Guaranteed outcomes: “guaranteed listing reinstatement” or “guaranteed Amazon approval”. Platforms make their own decisions; nobody can guarantee them.
Certificates or reports without testing: there is no such thing as a “GPSR certificate”, and test reports should come from a lab that tested the actual product.
Suggestions to borrow an address or invent a manufacturer: unlawful; do not do it.
No written mandate, or no copy for you: without a written mandate, the company is not legally your authorised representative.

Costs

There is no official price. Providers charge per product type, per SKU, per brand bundle or as one-off fees.

A single-source example: in November 2026 we checked the public GPSR authorised representative price list on one provider's website (not named, as we do not recommend providers). It charges by product type, from about EUR 199 a year for one product type to about EUR 1,790 a year for a 16-type bundle. That is one provider's published price, shown only to illustrate how pricing is structured. It is not a market average and not a recommendation. It excludes testing, translation and legal fees and can change at any time, so rely on the written quote you receive.

When comparing quotes, ask:

Are extra SKUs or product types charged separately?
Are authority requests, translations and notifications included?
Are there set-up or document review fees?
Does the price rise on renewal, and is there a fee to leave?

Ten questions to ask before you sign

In which member state are you registered, and what are your company and VAT numbers?
Is the postal address you give a real office of your company?
Does the mandate expressly cover Article 4(3) of Regulation 2019/1020 and GPSR Article 16(2)? Can I see a sample?
How fast do you notify me of, and reply to, an authority request?
Which documents must I upload, where are they stored and how are they protected?
How do you carry out the regular checks required by Article 16(2)?
Which languages can you use with authorities, and with me?
What does the annual fee include, and what is extra?
If I switch provider, how will you handle requests about stock with your details?
Do you also act for cosmetics, medical devices or the UK, and on what basis?

This site does not recommend providers; use these questions to compare them yourself. Not sure you need one yet? Take the 3-step compliance check. To prepare the file your representative will ask for, see GPSR technical documentation.

Choosing your EU Responsible Person

Confirm the manufacturer (brand owner) will sign the mandate, and list the brands and products to cover.
Verify the provider is registered in an EU member state at a real address.
Get a sample mandate and confirm it covers GPSR Article 10(2) and Regulation 2019/1020 Article 4(3).
Prepare and hand over technical documentation, test reports, label and packaging files.
Fix response times, languages, fee scope and notice period in the contract.
Agree a transition plan and relabelling schedule for a future change of provider.
Update every EU listing and new production labels with the representative's details.
Keep a signed copy of the mandate and review the product list yearly.

Common mistakes

Comparing price, not the mandate
If the cheapest offer's mandate does not designate the provider for the Article 4(3) tasks of Regulation 2019/1020, it may not legally be your responsible person at all. Get a sample mandate first and check it against GPSR Article 10(2) and Article 4(3).
Signing, then never sending documents
The representative must verify your technical documentation and supply it when an authority asks (Article 4(3)(a) and (b)). Authority deadlines are often short, and chasing a factory for reports at that point is risky. Hand over the file, test reports and label artwork when you sign.
Switching provider without updating labels and listings
The new representative's name and addresses must go into every EU listing (Article 19) and onto new production (Article 16(3)). Agree in both contracts how existing stock with the old details is handled.

Frequently asked questions

Can one EU Responsible Person cover every EU country?

Yes. The law requires one economic operator established in the Union, and authorities in any member state can contact it. It does not automatically cover Great Britain, or products with their own regimes such as cosmetics and medical devices.

Does the representative really need my test reports?

The responsible person must verify that the technical documentation exists and be able to provide it on request, so genuine providers ask for the file, test reports and labels. Some accept a commitment to supply on request, but authority deadlines are often short, so handing them over in advance is safer.

Is the EU Responsible Person liable for my product?

Generally it does not take over product liability. The Commission's Article 4 guidelines say the manufacturer remains responsible for compliance; the representative performs the tasks the law assigns, such as supplying documents, reporting risks and cooperating on corrective action. Indemnities and caps depend on your contract.

What happens to stock with the old representative's address if I switch?

Neither the regulation nor the Commission guidance addresses this transition specifically. Agree a transition period in which the old provider forwards related authority requests, and update listings and new batches quickly. Get legal advice for your situation.

Why do prices differ so much?

Differences usually reflect whether the provider actually reviews and holds your documents, whether authority requests and translations are included, response times, language support and the number of products covered. A cheap address-only service may be unable to act when an authority writes.

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.