What is an economic operator under GPSR and how do I know which role I have?

An economic operator under the General Product Safety Regulation (EU) 2023/988 (GPSR) is any business in the supply chain that has specific legal duties relating to product safety and cooperation with EU authorities. Your role depends on what you do for a given product—for example, manufacturing, importing into the EU, distributing, or fulfilling orders. Below is how to identify your role, how roles differ, and what an EU-based Responsible Person service typically does in practice.

What is an economic operator under the GPSR (EU) 2023/988?

Under the GPSR, an economic operator is a business that places products on the EU market or makes them available and therefore has defined product safety obligations. The GPSR recognises multiple economic operator roles, and one company can hold more than one role for different products or activities.

Manufacturer
Authorised representative (optional, based on a written mandate)
Importer (EU-established, bringing products from outside the EU)
Distributor (making products available after import or manufacture)
Fulfilment service provider (warehousing plus other logistics services, without owning the goods)
Other persons subject to obligations under the GPSR, depending on the activity

Obligations are role-specific, and they can apply in parallel when you perform multiple functions within the same supply chain.

How do I know which economic operator role I have for a product?

You can identify your GPSR role by following the product and the commercial decisions around it, not just by looking at who ships it. The fastest way is to check where each entity is established, who brands the product, and who first makes it available in the EU.

Do you sell under your own name or trademark? If yes, you are usually the manufacturer for GPSR purposes, even if another factory makes it.
Are you established in the EU and the first to bring the product from a non-EU country into the EU market? If yes, you are the importer.
Do you buy from an EU importer or EU manufacturer and resell without changing the product or brand? If yes, you are a distributor.
Do you provide at least two of these services without owning the product: warehousing, packaging, addressing, dispatch? If yes, you are a fulfilment service provider (postal, parcel delivery, and freight transport alone are excluded).

Common e-commerce scenarios:

Direct-to-consumer from outside the EU: the non-EU brand is typically the manufacturer, and an EU-based Responsible Person must be designated.
Marketplace selling: the seller still has economic operator duties, and marketplaces may request Responsible Person details as a condition of listing.
EU fulfilment warehouse: the warehouse operator may be a fulfilment service provider, and in some setups, it can become the Responsible Person if no other EU-based economic operator is available.

What are the key differences between manufacturer, importer, distributor, and responsible person under the GPSR?

The manufacturer carries the broadest product safety responsibilities, while importers and distributors add verification, traceability, and cooperation duties based on their position in the chain. The Responsible Person is an EU-established economic operator that must exist for products covered by the GPSR when the manufacturer is outside the EU.

Role	Core GPSR focus	Typical practical duties
Manufacturer	Design and place only safe products on the market	Risk assessment, technical documentation, traceability, corrective actions and recalls, cooperation with authorities
Importer	Gatekeeper for non-EU goods entering the EU market	Verify that required information is present, ensure traceability, cooperate with authorities, support corrective actions
Distributor	Safe supply and traceability at the resale stage	Act with due care, keep traceability information, cooperate with authorities, help with corrective actions when needed
Responsible Person	EU contact point and documentation availability	Make required documents available to authorities on request, support communication and corrective actions, ensure required contact details are provided

The Responsible Person concept under the GPSR is distinct from an authorised representative under other EU product legislation. An authorised representative is not mandatory, but a Responsible Person is required where the GPSR requires an EU-based economic operator. Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), the Responsible Person must notify the manufacturer of risks in line with Article 4, and the authorised representative role is the one associated with notifying serious risks to authorities where required.

How can an EU-based responsible person service support GPSR compliance?

An EU-based Responsible Person service supports GPSR compliance by providing a stable, EU-established economic operator function that helps keep required safety information organised, accessible, and ready for market surveillance requests. It does not replace the manufacturer’s duty to ensure the product is safe, but it can make compliance operationally manageable across many listings and Member States.

Documentation checks, verifying the presence and completeness of required product safety documents
Document availability, storing and making documentation available to authorities upon request
Authority communication support, handling incoming requests and coordinating timely responses
Corrective action support, helping coordinate safety communications, withdrawals, and recalls when the manufacturer initiates them
Label and listing readiness, confirming that required EU contact details and traceability information are correctly provided

How EARP helps with GPSR economic operator and responsible person requirements

We help you determine the correct economic operator setup for each product and implement the GPSR Responsible Person requirement in a way that works for online and offline EU sales. Our work is practical and documentation-focused, so you can keep products listed while staying ready for market surveillance checks.

We provide independent EU Authorised Representative and Responsible Person coverage where applicable
We verify that required product safety documentation is present and organised for authority requests
We support communication workflows for market surveillance questions and corrective actions

Review our services, then contact us to discuss your products and selling model.