We are a US company with our US address on the packaging, is that enough or do we need an EU address?

Default hero background
Uncategorized
Jason van de Zande

A US address on packaging is not enough for most consumer products sold in the European Union in 2026. In addition to your US manufacturer details, EU rules typically require an EU-based economic operator address on the product or packaging, such as an EU Responsible Person address, so authorities and consumers can reach a contact established in the EU.

This requirement is driven by the General Product Safety Regulation (EU) 2023/988 (GPSR) and, for many products, by product-specific laws that also require EU traceability details. If you sell directly into the EU without an importer or distributor, you often need to appoint an EU-based entity to fill that role.

The questions below explain when you need an EU address, what the GPSR packaging address requirements look like in practice, and how to label correctly without creating new compliance risks.

Is a US address on packaging enough to sell consumer products in the EU?

A US address on packaging is usually not sufficient for EU market access compliance because EU rules commonly require an EU economic operator to be identifiable by name and address on the product, packaging, or accompanying documentation. For many consumer products, that EU contact is the EU Responsible Person address required under GPSR.

In practical terms, EU authorities want a reachable, established-in-the-EU contact point for product safety and traceability. A non-EU manufacturer address helps identify who made the product, but it does not meet the EU requirement to have an EU-based operator that can cooperate with market surveillance.

This becomes especially important for online sales. If you ship directly from the United States to EU consumers and you do not have an EU importer or distributor in your supply chain, there may be no EU entity available to appear on the label. That is when sellers run into listing blocks and documentation requests from marketplaces.

Also note the terminology: an EU Authorized Representative label is not automatically the same thing as a Responsible Person label. An authorized representative can exist for certain regulatory frameworks, but under GPSR the key concept for many sellers is having the required EU-based economic operator identified for consumer product safety purposes.

When do you need an EU Responsible Person or other EU economic operator address on the product?

You need an EU Responsible Person address or another EU economic operator address when EU law requires an EU-established contact for the product you place on the market, and your supply chain does not already provide one. Under GPSR, many non-EU sellers must ensure an EU-based economic operator is designated and identifiable, especially when selling directly to consumers.

Common situations where this comes up include:

  • Direct to consumer shipping into the EU with no EU importer or distributor involved
  • Online marketplace sales where platforms request proof of an EU Responsible Person address before allowing listings
  • Mixed catalogs where some products fall under additional EU rules that also require EU traceability details

The phrase “economic operator” matters because the role is taken by an organization established in the EU, not an individual. Depending on your setup, the economic operator shown on the product could be an importer, a distributor, or a designated Responsible Person entity.

It is also important to understand the EU importer vs responsible person distinction. An importer is typically the EU entity that brings goods from outside the EU into the EU market and takes on importer obligations. A Responsible Person is an EU-established economic operator designated to fulfill specific compliance and cooperation functions when there is no other suitable EU operator in the chain.

Finally, coordination with the Market Surveillance Regulation (EU) 2019/1020 (MSR) can matter for how authorities request information and how the designated economic operator supports compliance. Under MSR Article 4, the Responsible Person role includes notifying the manufacturer of risks when identified, while the authorized representative role is the one associated with notifying serious risks to authorities in the relevant frameworks.

What exactly must appear on the label or packaging for EU compliance?

For EU compliance, the label or packaging must provide clear traceability and contact information, typically including the manufacturer’s identification and an EU-based economic operator name and address when required. GPSR packaging address requirements focus on making it easy for consumers and authorities to identify the product and reach the correct EU contact.

While exact label content can vary by product type and applicable legislation, a practical compliance checklist often includes:

  • Product identification such as model, type, batch, or serial number to support traceability
  • Manufacturer name and postal address such as your US company details
  • EU economic operator name and postal address such as the EU Responsible Person address when required
  • Safety information and warnings appropriate to the product and foreseeable use conditions
  • Instructions for safe use in the required language(s) for the target EU markets where applicable

Placement also matters. Many rules expect key traceability details to appear on the product itself when feasible. If that is not possible due to the size or nature of the product, the information may be allowed on the packaging or in accompanying documentation. The goal is that the information remains available throughout distribution and use.

Avoid common mistakes that trigger marketplace or authority questions:

  • Using only a website or email instead of a postal address for the EU contact
  • Listing an EU logistics warehouse that is not actually the designated economic operator
  • Mixing roles on the label, for example calling an entity an authorized representative when the required role is a Responsible Person under GPSR
  • Failing to keep supporting documentation organized and retrievable if authorities request it after an accident or complaint

Because labeling interacts with documentation, you should also ensure your technical file and product safety documentation are complete and can be made available promptly when requested by market surveillance authorities.

How can EARP help you add the right EU address and stay compliant?

We help non-EU manufacturers and sellers meet EU market access compliance by providing an independent EU-based economic operator solution aligned with GPSR, including setting up the correct EU Responsible Person address for labeling and ensuring your documentation and processes support market surveillance requests. We focus on fast, practical compliance so you can keep selling without guesswork.

  • Confirm what address is required for your products and sales model, including the EU importer vs responsible person implications
  • Provide an EU Responsible Person address suitable for packaging and listings where GPSR requires it
  • Verify documentation readiness by checking the presence and completeness of required product safety documents and keeping them available for authorities when requested
  • Support marketplace compliance by helping you align product pages and packaging details with platform verification workflows

To get started, review our EU compliance services and then share your product and sales details through our contact form so we can confirm the right labeling approach and next steps.

Related Articles