Do I need a Responsible Person for products that are already CE marked?

Yes, you may still need an EU responsible person even if your product is already CE marked. CE marking shows conformity with specific EU harmonisation legislation, but it does not remove the separate requirement to have an EU-based economic operator identified for product safety and market surveillance purposes. Below are the most common questions sellers ask about how CE marking, Authorised Representatives, and GPSR responsible person duties fit together.

Do CE-marked products still need an EU Responsible Person under GPSR?

In many cases, yes. CE marking does not replace GPSR obligations. CE marking indicates that the product meets the applicable EU harmonisation legislation that requires CE marking, but consumer products can still fall under the General Product Safety Regulation (EU) 2023/988 (GPSR) for general safety duties and traceability requirements.

Under the GPSR, products placed on the EU market must have an EU-based economic operator whose contact details are available, so authorities can request information and take action when needed. Depending on the product and supply chain, that EU-based operator can be the manufacturer (if established in the EU), an importer, a distributor, a fulfilment service provider, or an appointed responsible person.

Also note that some CE-marking laws have their own “economic operator” rules, so you may have overlapping obligations: one set under sector legislation and another under the GPSR and market surveillance rules.

What is the difference between CE marking, an Authorised Representative, and a GPSR responsible person?

They are related but not the same. CE marking is a product marking, an Authorised Representative is a role defined in certain sector laws, and a GPSR responsible person is an EU-based economic operator that performs specific market-access and cooperation tasks.

Term	What it is	What it does not mean
CE marking	A marking showing conformity with applicable EU harmonisation legislation that requires CE marking.	It is not proof that you have an EU responsible person in place.
Authorised Representative	An EU-established representative appointed under certain sector legislation, with tasks defined by that law and the mandate.	It is not automatically required for every CE-marked product, and it is not interchangeable with a GPSR responsible person unless the law allows it.
GPSR responsible person	An EU-based economic operator identified for GPSR purposes, with duties such as ensuring documentation is available and cooperating with authorities.	It is not the manufacturer, and it is not a substitute for CE compliance work.

One entity can sometimes hold more than one role, but only when the legal framework and mandate allow it. Treat them as separate compliance building blocks, not synonyms.

When can an importer or distributor act as the Responsible Person, and what information must appear on the product?

An importer or distributor can act as the responsible person when they are the relevant EU-based economic operator in your supply chain and the legal conditions are met. If you sell directly to EU consumers from outside the EU, and there is no EU importer taking responsibility, you often need to appoint an EU-based responsible person to avoid a “no EU operator” gap.

Common supply-chain outcomes

EU importer present: the importer is typically the key EU economic operator for many obligations and may satisfy the “EU operator” requirement.
EU distributor only: the distributor has verification duties before making the product available, but may not always be the right operator to rely on for responsible person coverage.
No importer or distributor (distance sales): you generally need an appointed EU responsible person, or an EU fulfilment service provider may become the responsible person by operation of law if no other EU operator exists.

What must be shown to consumers and authorities

On the product, packaging, or accompanying document: the responsible person’s name, postal address, and electronic contact details.
Online listing consistency: product and economic operator details should match what is on the label or packaging.
Documentation readiness: the responsible person must be able to provide product safety and compliance documentation to market surveillance authorities upon request, in a language the authority can understand.

Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), the responsible person must also inform the manufacturer when there is reason to believe a product presents a risk, so corrective action can be taken.

How does EARP help with Responsible Person compliance for CE-marked products sold in the EU?

We help you stay compliant when CE-marked products still require an EU responsible person and clear economic operator traceability under the GPSR and MSR. Our support is practical and documentation-focused, so you can keep listings and shipments aligned with EU requirements.

Confirm whether the GPSR responsible person requirement applies to your product and sales model
Check the presence and completeness of required product safety documentation, and set up a clear document set for authority requests
Act as your EU responsible person, and provide our EU contact details for labels, packaging, or accompanying materials
Store technical documentation and provide it to authorities when requested
Support marketplace compliance workflows that ask for responsible person details

See our services for details, or contact us to confirm the fastest compliant path for your CE-marked products.