Do I need a Responsible Person if I already have an EU based importer?

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Jason van de Zande

If you already have an EU-based importer, you may already have a responsible person for products covered by the General Product Safety Regulation (EU) 2023/988 (GPSR), because the importer is often the EU economic operator that fulfils that role. However, this is not automatic in every sales model, and importers may not accept all GPSR tasks in practice. Below are the key differences, when you still need a separate responsible person, and what to check on your labelling and documentation.

Does having an EU-based importer mean I already have a GPSR Responsible Person?

Often yes, because under the GPSR, a product generally cannot be placed on the EU market without an EU-established economic operator acting as the responsible person, and the importer is typically first in line when the manufacturer is outside the EU. However, having an importer does not guarantee that they will act as the responsible person for every channel, SKU, or brand, and their details must be identifiable on the product, packaging, or an accompanying document.

Practical checks you can do quickly:

  • Confirm scope: Does the importer cover all EU countries, all listings, and all product variants?
  • Confirm labelling: Is the responsible person’s name, postal address, and electronic contact information shown on the product or packaging (or on an accompanying document, where allowed)?
  • Confirm access to documentation: Can the importer make the required technical documentation available to authorities on request, in a language the authority can understand?

What is the difference between an importer and a GPSR Responsible Person under EU law?

An importer is the EU entity that places products from a third country on the EU market. A responsible person is an EU-established economic operator designated (or determined by the legal hierarchy) to perform specific GPSR compliance tasks and serve as a contact point for authorities. One company can hold both roles, but the roles are not automatically interchangeable across all supply chains and sales models.

Role Main focus under GPSR Typical practical obligations
Importer Gatekeeper before placing on the market Ensures the product meets the general safety requirement; checks that the manufacturer has carried out a risk analysis and prepared technical documentation; adds importer contact details; cooperates with authorities; and helps ensure corrective measures are taken when needed.
Responsible person EU compliance contact point and documentation availability Verifies that technical documentation exists and can be provided to authorities on request; cooperates with market surveillance authorities; ensures corrective action is taken when required; and informs the manufacturer when there is reason to believe a product presents a risk (linked to duties under the Market Surveillance Regulation (EU) 2019/1020 (MSR)).

Also note the separation of roles around notifications: the responsible person role is not the same as the authorised representative role, and notification duties differ depending on which role is appointed and which legal framework applies.

When do I still need to appoint a separate Responsible Person even with an importer?

You may still need to appoint a separate responsible person when your importer is not actually the EU economic operator for a given sales flow, or when they will not contractually and operationally perform the responsible person tasks for all products you place on the market. This is common in modern e-commerce supply chains, where “importer” status can vary by shipment, destination, or fulfilment setup.

  • Direct-to-consumer shipments where there is no importer placing the product on the EU market in the classic sense.
  • The importer refuses the role or will not hold and provide technical documentation to authorities on request.
  • Multiple importers across the EU, creating inconsistent labelling, documentation control, and authority contact points.
  • Marketplace enforcement where platforms request responsible person details and evidence at the listing or brand level, even if you have an importer somewhere in the chain.
  • Supply chain changes such as switching importers, using new fulfilment providers, or adding new EU countries, which can break continuity if the responsible person function is tied to a single commercial partner.
  • Other EU legislation applies (for example, CE-marking frameworks) where you may choose to appoint an authorised representative for defined tasks, and that authorised representative can also be designated to act as the responsible person, where appropriate.

The recurring issue is not the title; it is whether an EU-established operator can reliably make documentation available and act as a consistent contact point for market surveillance authorities.

How EARP helps with GPSR Responsible Person requirements when you already have an EU importer

If you already have an importer but still need a stable, independent responsible person function, we can step in as your EU-based Responsible Person under the GPSR and support the compliance workflow without being tied to your commercial distribution choices.

  • Act as an independent EU Responsible Person and authority contact point.
  • Verify that the required product safety documentation is present and complete, then store it and make it available to authorities upon request.
  • Support marketplace compliance by providing the responsible person details needed for listings and account checks.
  • Help maintain continuity when you change importers, distributors, or fulfilment setups.

See our GPSR services for what we cover, or contact us to confirm whether your current importer arrangement fully satisfies responsible person requirements for your specific sales channels.

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