Why does the EU require a Responsible Person for products sold in Europe?

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Jason van de Zande

The EU requires a responsible person so that market surveillance authorities always have an EU-based economic operator they can contact quickly about a product’s safety, traceability, and documentation. This is especially important for online and distance sales, where the seller may be outside the EU. Below are the key questions businesses ask about what the responsible person is, when it is required, and what it must do under the General Product Safety Regulation (EU) 2023/988 (GPSR).

What is an EU Responsible Person and when is one required?

An EU responsible person is an economic operator established in the EU that is designated to carry out specific product-safety tasks for products placed on the EU market. Under the GPSR, this requirement applies broadly to consumer products, including products offered through distance and online sales to EU consumers.

The responsible person role can be fulfilled by an EU-established:

  • Manufacturer (if the manufacturer is established in the EU)
  • Importer (when products are brought in from outside the EU and an EU importer places them on the market)
  • Authorised representative (when appointed by a non-EU manufacturer under a written mandate and used to fulfil the responsible person function)
  • Fulfilment service provider (may become the responsible person when no other EU-based economic operator is in place)
  • Another EU-based entity, where the legal conditions allow it

Sector-specific EU laws may use different “responsible entity” concepts and may add role-specific obligations (for example, CE-marking legislation for certain product categories). The GPSR responsible person requirement does not remove those additional duties.

Why does the EU require a Responsible Person for products sold in Europe?

The EU requires a responsible person to ensure there is a reliable EU-based contact point for enforcement and safety action. When a product raises concerns, authorities need a party in the EU that can respond quickly, provide documentation, and support corrective measures. This improves consumer protection and makes the rules enforceable for non-EU sellers and online sales.

In practice, the policy goals include:

  • Faster authority contact: an EU-established operator can be reached without cross-border delays.
  • Accountability for documentation: authorities can request safety information and expect a timely response.
  • Traceability: clear identification of the product and the operators behind it supports investigations and targeted actions.
  • More effective marketplace enforcement: online marketplaces can request proof of an EU responsible person as part of listing controls.

This approach aligns with the Market Surveillance Regulation (EU) 2019/1020 (MSR), which strengthens how authorities supervise products sold in the EU, including those sold online.

What does the Responsible Person have to do under GPSR?

Under the GPSR, the responsible person must be able to support product-safety compliance by making key information available and cooperating with market surveillance authorities. The exact tasks depend on which economic operator holds the role and the product’s legal framework, but the role is not a “certification” function and does not approve products.

Common responsibilities include:

  • Verifying that required product information is present, such as manufacturer identification, product identifiers (type, batch, serial, or equivalent), and required warnings and instructions.
  • Ensuring technical documentation and the manufacturer’s internal risk analysis are available to authorities upon request and can be provided without undue delay.
  • Cooperating with market surveillance authorities on requests, checks, and follow-up actions.
  • Supporting corrective actions, such as withdrawals, recalls, and consumer safety communications, when needed.
  • Maintaining communication channels so that safety-related information can be exchanged efficiently.

Under Article 4 of the MSR, when the responsible person becomes aware of a risk, the responsible person must notify the manufacturer. Notification of serious risks to authorities is not a responsible person duty under that MSR provision.

How EARP helps with EU Responsible Person compliance under GPSR

When you need an EU-based responsible person to keep products available to EU customers, [COMPANY] provides dedicated GPSR Responsible Person services focused on documentation readiness and communication with authorities. We support non-EU manufacturers, brands, and sellers with practical steps that meet marketplace and enforcement expectations.

  • Responsible Person appointment support and guidance on what information must appear on product labels, packaging, and instructions
  • Documentation presence and completeness checks for GPSR readiness (including risk analysis and technical documentation availability)
  • Secure documentation storage and controlled release to authorities upon request
  • Liaison with EU market surveillance authorities, including structured handling of information requests
  • Support for online marketplace documentation workflows and consistency checks across listings and product identifiers

To review options, visit our services page, or contact us to discuss your product and sales model.

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