What questions should I ask before hiring a Responsible Person provider?

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Jason van de Zande

Before hiring a responsible person provider, ask questions that confirm they are legally established in the EU, can take on the GPSR role for your product type, and can respond quickly to authorities and marketplace checks. You also want clarity on what they will store, verify, and provide on request, as well as how they handle product safety risks and accidents. The questions below help you compare providers by scope, independence, documentation control, and service levels.

What is a GPSR Responsible Person and when do you need one?

A GPSR responsible person is an EU-established economic operator designated to perform specific product-safety cooperation and documentation tasks under the General Product Safety Regulation (EU) 2023/988 (GPSR). You need one when placing GPSR-covered consumer products on the EU market and your business is not established in the EU; in that case, an EU-based operator must be available for market-surveillance contact and document access.

Under the GPSR, the responsible person role is held by an economic operator, not an individual. Depending on your supply chain, it can be the EU manufacturer, the importer, an authorised representative with a written mandate, or, in some cases, a fulfilment service provider if no other EU-based operator exists.

Role What it is (high level) Common confusion to avoid
Responsible person EU economic operator for defined GPSR cooperation and documentation tasks Not the same as the customs “Importer of Record”
Authorised representative EU entity with a written mandate to act for a non-EU manufacturer for specified tasks Not mandatory in all cases, but can be designated as the responsible person
Importer EU entity that places a product from a third country on the EU market Different from courier customs-clearance arrangements

What questions should you ask to verify a Responsible Person provider’s legal scope and independence?

Start by confirming that the provider can legally act as the responsible person for your products and that their role is not compromised by commercial interests. A good provider will clearly explain what they can and cannot do under the GPSR, how they are established in the EU, and how they avoid conflicts that can arise when the same company is also an importer, distributor, or seller of competing products.

  • Are you established in the EU, and in which country is your legal entity registered?
  • Will you provide a written mandate or contract that explicitly designates you as the responsible person for the listed products?
  • Are you also acting as an importer, distributor, fulfilment service provider, or marketplace seller for any of our products, or do you remain independent?
  • How do you handle situations where a fulfilment provider could become the responsible person by operation of law, and how do you prevent role confusion?
  • What is your process for communicating with national market-surveillance authorities, and in which languages can you respond?
  • How do you handle confidentiality and access control for technical documentation?

Also ask how the provider aligns responsibilities with the Market Surveillance Regulation (EU) 2019/1020 (MSR), especially the duty to notify the manufacturer of risks under Article 4 when they have reason to believe a product presents a risk.

What documentation, processes, and response times should a Responsible Person provider commit to?

A responsible person provider should commit to practical, testable processes: what they will store, what they will verify, how fast they will respond, and how they will support corrective actions. The GPSR expects technical documentation to be available to authorities on request, and marketplaces often check that labels, listings, and documents are consistent. You should require clear service levels and escalation paths.

  • What technical documentation do you require for onboarding, and do you verify its presence and completeness before accepting the mandate?
  • How do you store documents, for how long, and how do you ensure they are quickly retrievable if an authority requests them?
  • What is your response time commitment for authority requests and marketplace escalations?
  • Will you review product labels and packaging to confirm that the responsible person’s name, postal address, and electronic contact details appear correctly?
  • How do you check document consistency across labels, instructions, test reports, and product identifiers used in listings?
  • What is your process for handling accidents, complaints, and emerging safety risks, including escalation to the manufacturer and support for corrective actions such as withdrawal or recall?
  • Who is the day-to-day contact, and what happens if that contact is unavailable?

How EARP helps with choosing and working with a GPSR Responsible Person provider

We help you appoint and work with a GPSR responsible person by providing independent, EU-based representation and structured compliance support designed for non-EU businesses selling consumer products into the EU.

  • Clear onboarding to confirm scope and required documentation, plus structured document storage and retrieval.
  • Independent Responsible Person and authorised representative support focused on regulatory cooperation, not sales or distribution.
  • Practical guidance on labelling and marketplace-ready evidence alignment, including consistency checks across identifiers.
  • Defined communication paths for authority requests, safety risks, and corrective action coordination.

Review our services, then contact us to discuss your products and set up the right Responsible Person arrangement for EU market access.

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