Does my Responsible Person check my products for safety before I can sell them?

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Jason van de Zande

A GPSR responsible person does not “approve” your product for sale by testing it. Under the General Product Safety Regulation (EU) 2023/988 (GPSR), the responsible person is an EU-based economic operator that helps ensure required safety information and technical documentation exist, are complete, and can be provided to authorities on request. Before selling, you should have a risk assessment, traceability details, and correct labels, warnings, and instructions ready.

Does a GPSR responsible person test or certify my product before sale?

No. A GPSR responsible person does not test, certify, or “sign off” on your product before you sell it. The role focuses on documentation readiness and cooperation with EU market surveillance authorities, not laboratory testing or product certification.

In practice, a responsible person typically checks whether the manufacturer has drawn up technical documentation and whether it can be made available promptly when requested. This is different from:

  • Product testing, which is performed by the manufacturer or a test laboratory.
  • Certification, which may be required under certain sector laws and can involve a notified body, depending on the product.
  • CE marking and conformity assessment, which apply only where specific EU harmonisation legislation requires them, not because of GPSR alone.

A responsible person is not a notified body and does not issue certificates. The manufacturer remains responsible for ensuring the product is safe and for generating the evidence that supports that conclusion.

What safety information and documents should be ready before you sell in the EU?

You should have a clear, product-specific safety file ready before listing or shipping to the EU. Under the GPSR, the manufacturer must perform an internal risk analysis and draw up technical documentation that demonstrates the product is safe, then keep it available after placing the product on the market.

What “ready” looks like depends on the product and any applicable sector legislation, but commonly includes:

  • Product identification and traceability: type, batch, serial number, or other identifier, plus clear model and variant information.
  • Manufacturer details: name, registered trade name or trademark, postal address, and an electronic address (for example, an email address or a dedicated contact page).
  • Responsible person details shown on the product or packaging when the manufacturer is not established in the EU.
  • Risk assessment: hazards, foreseeable use and misuse, vulnerable users, and risk controls.
  • Technical documentation: product description, safety-relevant characteristics, applied standards (if any), and test report outcomes where appropriate.
  • Instructions and warnings in languages easily understood by consumers in each target Member State.
  • Online offer information for distance sales: identification, manufacturer and responsible person contact details, and required warnings displayed in the listing.

What happens if your responsible person finds missing or weak safety documentation?

If documentation is missing or weak, the responsible person will usually ask you to fill the gaps before continuing sales, especially where marketplaces or authorities may request evidence quickly. The goal is to avoid placing, or continuing to make available, products that cannot be supported with adequate safety information.

Typical outcomes include:

  1. Document requests: an updated risk assessment, clearer model and variant mapping, missing test evidence, or corrected labels and manuals.
  2. Corrective actions: improving warnings, adding mandatory contact details, or aligning identifiers across packaging, instructions, and listings.
  3. Operational holds: pausing shipments or holding a listing until the minimum evidence set is ready to upload for marketplace checks.
  4. Supply chain follow-up: contacting the manufacturer or OEM to obtain the right documents for the exact branded product and identifiers being sold.

If issues remain unresolved, consequences can include marketplace blocks, and market surveillance authorities can request information, inspect and test products, and order corrective measures. Staying responsive and keeping documentation current reduces the risk of disruption.

How EARP helps with GPSR responsible person compliance

At EARP, we act as your EU responsible person and help you stay ready for marketplace checks and authority requests by focusing on documentation completeness, availability, and clear communication.

  • We provide EU responsible person coverage aligned with the GPSR and the Market Surveillance Regulation (EU) 2019/1020 (MSR).
  • We perform structured completeness checks of your safety documentation and product information.
  • We store documentation and make it available to authorities upon request, using established processes.
  • We guide you on practical gaps, such as missing identifiers, language requirements for instructions, and listing information for distance sales.

Review our services, then contact us to set up your GPSR responsible person support.

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