Does my Responsible Person need to approve my packaging before I start selling?

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Jason van de Zande

A Responsible Person does not “approve” your packaging in the way a design agency or a regulator would. Under the General Product Safety Regulation (EU) 2023/988 (GPSR), the key practical requirement is that the required product and economic operator information is present, accurate, and consistent across the product, packaging, and online listing. Many sellers still ask their Responsible Person to review packaging before launch because marketplaces may block listings if labeling evidence is missing or inconsistent.

Does a GPSR responsible person have to approve packaging before you sell in the EU?

No, the GPSR does not require a formal pre-sale “approval” sign-off from the Responsible Person. What matters is that an EU-based Responsible Person (an economic operator) is designated when required, and that the required information can be verified and provided to authorities on request. In practice, “approval” usually means a packaging and label compliance review to reduce the risk of marketplace blocks and enforcement issues.

Marketplaces often treat packaging review as a gate, even when the law does not use that word. They may ask for photos showing the Responsible Person’s details on the product or packaging, and they may compare what is printed with what you entered in the listing. If your internal process requires a pre-launch check, treat it as a quality control step, not a legal sign-off.

What packaging and labeling information must be checked before placing a consumer product on the EU market?

Before you sell, check that the packaging and labeling contain the required identifiers, contact details, and safety information for your product type. The GPSR sets general product information expectations, and additional EU harmonisation legislation can add sector-specific markings and wording. The safest approach is to verify the minimum identity, traceability, and safety content first, then add any product-specific requirements.

  • Manufacturer identification: name, postal address, and an electronic contact address that enables direct, two-way communication (for example, an email address or contact form).
  • Product identification: model, type, or other identifier and, where applicable, a batch, lot, serial number, or equivalent traceability element.
  • Responsible Person details (when required): name and contact details, shown on the product, packaging, or an accompanying document, depending on what is feasible.
  • Importer details (if there is an EU importer): importer name and contact details, without obscuring other mandatory information.
  • Warnings and instructions: clear safety warnings and instructions for safe use, including foreseeable misuse where relevant.
  • Language requirements: safety information and instructions in the language(s) required in the Member State(s) where you sell.
  • CE marking (where applicable): only for products covered by CE-marking legislation, and only when all applicable requirements are met.
  • Online offer consistency: the same manufacturer and Responsible Person details, product identifiers, and warnings should also appear in the online listing where required.

What happens if your packaging is non-compliant after you start selling?

If packaging is non-compliant, you can face listing suppression or delisting by marketplaces, requests from market surveillance authorities for documents and explanations, and obligations to take corrective actions such as relabeling, withdrawal, or recall, depending on the issue. Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), the Responsible Person must inform the manufacturer if there is reason to believe a product presents a risk.

  1. Stop further shipments of the affected stock while you assess the gap.
  2. Identify the root cause: missing contact details, incorrect addresses, mismatched model numbers, missing warnings, or language gaps.
  3. Correct artwork and files, then relabel or repackage stock where feasible.
  4. Update online listings so the displayed manufacturer and Responsible Person details, identifiers, and warnings match the physical product.
  5. Prepare documentation so you can respond quickly if authorities or marketplaces request evidence.
  6. Coordinate with your Responsible Person on what to provide and how to document the corrective action trail.

How can EARP help with GPSR responsible person and packaging compliance?

We help you meet GPSR Responsible Person requirements and reduce packaging and listing compliance friction by providing an EU-based Responsible Person service and structured packaging and documentation checks aligned with the GPSR and relevant EU rules.

  • Acting as your EU Responsible Person where eligible
  • Reviewing labels and packaging content for required identity, traceability, and safety information
  • Checking the presence and completeness of key product safety documentation and storing it so it is available to authorities on request
  • Supporting responses to marketplace compliance requests and corrective action planning
  • Liaising with market surveillance authorities when they contact the EU economic operator

See our services for details, or contact us to discuss your product, packaging, and Responsible Person setup before you list in the EU.

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