Do UK companies need an EU Responsible Person after Brexit?
Yes, many UK companies need an EU-based responsible person to keep selling consumer products in the EU after Brexit. Under the General Product Safety Regulation (EU) 2023/988 (GPSR), products placed on the EU market must have an EU-established economic operator that can perform the responsible person tasks and cooperate with market surveillance authorities. The key factors are where you sell, which products you sell, and whether you sell into the EU or only in Great Britain, with Northern Ireland following different rules.
Do UK companies need an EU Responsible Person to sell in the EU after Brexit?
Yes. If a UK business places consumer products on the EU market and is not established in the EU, it must ensure there is an EU-established economic operator fulfilling the responsible person role required by the GPSR. This applies whether you sell via EU distributors or through distance selling directly to EU consumers. If you sell only in Great Britain, EU responsible person rules do not apply.
For Northern Ireland, the position can differ because certain EU product rules continue to apply under the Windsor Framework. If you supply Northern Ireland, check whether your product falls under EU rules for that route, and do not assume Great Britain and Northern Ireland obligations are identical.
- Selling into the EU (including online): plan for an EU-established responsible person.
- Selling only in Great Britain: EU responsible person requirements generally do not apply.
- Northern Ireland: verify the applicable framework for your specific product and supply route.
Which products and sales channels trigger the EU Responsible Person requirement?
The EU responsible person requirement is triggered when products within the GPSR’s scope are made available on the EU market, including through online distance selling. The GPSR is a horizontal consumer product safety framework that applies broadly to consumer products, including products intended for professional use that could reasonably end up being used by consumers. Selling on EU marketplaces or shipping directly to EU consumers are common triggers.
Sector-specific EU laws can add obligations beyond the GPSR. For example, medical devices and cosmetics have their own regulatory frameworks and designated roles. Even when product-specific rules apply, the GPSR can still matter as the general safety baseline for consumer products where relevant.
- Listing products on EU marketplaces (for example, EU Amazon stores, eBay, Etsy, or other EU-facing platforms).
- Shipping direct-to-consumer orders from the United Kingdom to EU Member States.
- Using EU fulfilment or warehousing arrangements that support EU sales.
What is the difference between an EU Responsible Person, an EU Authorized Representative, and an importer?
An EU responsible person is an EU-established economic operator that performs specific cooperation and documentation-availability tasks for products sold in the EU. An EU Authorized Representative is an EU-established entity appointed by a non-EU manufacturer under a written mandate to carry out defined regulatory tasks, and it may be chosen to act as the responsible person. An importer is an EU-established entity that places a product from a third country on the EU market.
| Role | Who it is | What it does (high level) |
|---|---|---|
| Responsible person | EU-established economic operator | Holds or can access required safety documentation, cooperates with authorities, and helps ensure required information is available when requested. |
| Authorized Representative | EU-established entity with a written mandate | Performs tasks defined in the mandate, can act as a liaison with authorities, and may also take on the responsible person role. |
| Importer | EU-established supply chain actor | Places third-country goods on the EU market and has importer obligations, but may not be willing or able to take on the responsible person role for your brand. |
Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), the responsible person must inform the manufacturer when it becomes aware of risks. Notification of serious risks to authorities is not a responsible person duty under MSR Article 4; it is associated with the Authorized Representative role where applicable.
How does EARP help with EU Responsible Person requirements after Brexit?
When you need an EU-established responsible person for GPSR compliance after Brexit, [COMPANY] provides practical, documentation-focused support so you can keep EU listings and shipments compliant without building your own EU presence. We support non-EU manufacturers, brands, and online sellers with clear processes aligned with GPSR and MSR expectations.
- Acting as your EU responsible person under the GPSR, where applicable
- Structured onboarding to confirm required product safety documentation is present and complete
- Secure technical documentation storage and controlled availability to market surveillance authorities upon request
- Marketplace compliance support, including aligning responsible person details with labels and listing evidence
- Ongoing liaison with national authorities for regulatory cooperation and documentation requests
Review our EU compliance services, then use our contact page to tell us what you sell and where you ship in the EU, and we will confirm the fastest path to meeting the responsible person requirement.
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