Do Chinese manufacturers selling directly to EU consumers need a Responsible Person?

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Jason van de Zande

Yes. If a Chinese manufacturer sells consumer products directly to EU consumers, including through online marketplaces, the product generally cannot be made available in the EU unless there is a responsible person established in the EU. This requirement comes from the General Product Safety Regulation (EU) 2023/988 (GPSR) and is closely linked to the Market Surveillance Regulation (EU) 2019/1020 (MSR). Below are the practical triggers, what “placing on the market” means for China-to-EU shipping, and what information must appear on labels and packaging.

Do Chinese manufacturers selling directly to EU consumers need an EU Responsible Person?

In most cases, yes. When a non-EU manufacturer places a consumer product on the EU market, the EU framework requires an EU-established economic operator to take on the responsible person role for that product. This applies to distance sales, direct-to-consumer shipping, and marketplace sales where the offer targets EU consumers. The responsible person is not an individual; it is a legally established entity in the EU.

Who can act as the responsible person depends on your supply chain and the applicable product legislation. Common options include:

  • Your own EU-established manufacturing entity (if you have one).
  • An EU importer (when there is an importer placing the product on the EU market).
  • An authorised representative (optional as a role, but it can be designated to cover responsible person tasks where permitted).
  • An EU fulfilment service provider may become the responsible person by operation of law if no other EU-based economic operator exists for the product.

What counts as placing a product on the EU market when you ship from China?

Placing on the market generally means supplying a product for the first time for distribution, consumption, or use in the EU in the course of a commercial activity. Making available is broader; it covers any supply of a product for distribution, consumption, or use in the EU. If your online offer is directed at EU consumers and consumers can conclude a distance contract, the product is typically treated as being made available in the EU and must meet EU safety and sector-specific rules before sale.

This matters for common China-to-EU models:

  • Direct shipping from China to an EU consumer: the offer and sale can still trigger EU product safety obligations.
  • Marketplace sales (for example, Amazon or eBay): listings are often reviewed for responsible person details and label consistency.
  • EU fulfilment (warehousing and shipping from the EU): the fulfilment service provider has defined product safety obligations and can become the responsible person if no other EU operator exists.

Practical takeaway: align your listing, label, manual, and product identifiers, because mismatches are a common reason for compliance rejections and authority questions.

What information must the Responsible Person provide and where must it appear?

The responsible person must be able to support market surveillance with product safety information and cooperation. Under the GPSR and the MSR Article 4 framework, the responsible person typically ensures that the required technical documentation exists and can be provided to authorities on request, cooperates with market surveillance authorities, and supports traceability and corrective actions when safety concerns arise. The responsible person must also notify the manufacturer when there is reason to believe a product presents a risk, as set out in the MSR.

In practice, responsible person obligations commonly include:

  • Verifying that required product safety documentation is available and can be supplied to authorities upon request.
  • Cooperating with market surveillance authorities during checks and investigations.
  • Handling safety complaints and tracking accident information so it can be escalated appropriately.
  • Supporting corrective actions such as withdrawals, consumer warnings, and recalls when needed.

The responsible person’s name and contact details must appear on the product or, where that is not possible, on the packaging or in an accompanying document. Marketplaces and authorities also expect the information to be easy to find and usable, including a postal address and an electronic contact point, and safety information should be available in a language that consumers can understand in the target Member State.

How EARP helps with EU Responsible Person and GPSR compliance

We help non-EU manufacturers and sellers meet GPSR responsible person requirements with a structured, documentation-first process. See our services for the full scope, or contact us to confirm fit for your product category and sales model.

  • Eligibility check for GPSR scope and any sector-specific EU rules that also apply.
  • Documentation gap review focused on required product safety documents and consistency across labels, manuals, and listings.
  • Responsible person appointment and mandate setup, with clear responsibilities and communication routes.
  • Label and packaging wording support so responsible person details appear in the correct place and format.
  • Technical file storage and controlled access, so documentation can be provided to authorities when requested.
  • Liaison support with market surveillance authorities, including handling information requests and follow-up actions.
  • Support for safety complaint handling, accident escalation, and recall coordination when required.

If you are selling from China into the EU and need an EU-established responsible person, use our contact page to tell us your product type, sales channels, and fulfilment model.

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