What is the difference between EU Authorized Representative and Responsible Person?

The main difference between an EU Authorized Representative and a Responsible Person lies in their regulatory scope and application. An Authorized Representative operates under specific EU directives like CE marking regulations, whilst a Responsible Person functions under the General Product Safety Regulation (EU) 2023/988 (GPSR) for broader product safety compliance. Both serve as mandatory EU-based contact points for non-EU manufacturers, but they address different regulatory frameworks and responsibilities.

Understanding the basics of EU compliance representation

When you sell products in the European Union as a non-EU manufacturer, you must appoint an EU-based representative to handle regulatory compliance and serve as your official contact point with authorities. This requirement stems from the EU’s approach to market surveillance and consumer protection.
The regulatory landscape includes multiple frameworks that govern different aspects of product safety and compliance:

Harmonised legislation – covers specific product categories through CE marking requirements
General Product Safety Regulation – addresses broader safety obligations across virtually all consumer products

These representation requirements ensure that EU authorities can effectively communicate with manufacturers, access necessary documentation, and take swift action when safety concerns arise. Without proper representation, you cannot legally place your products on the EU market, and online marketplaces like Amazon will not permit sales.

What is an EU Authorized Representative?

An EU Authorized Representative is a legal entity established within the European Union that acts on behalf of non-EU manufacturers under specific EU directives and regulations. This role applies primarily to products subject to CE marking requirements, including:

Electronics
Machinery
Medical devices
Toys

The Authorized Representative’s responsibilities centre around maintaining compliance documentation and facilitating communication with regulatory authorities. They must hold your Declaration of Conformity, technical files, and other required documentation, making these available to authorities upon request.
You need an Authorized Representative when your products fall under harmonised EU legislation that specifically requires this role. Common examples include:

Electromagnetic Compatibility Directive (EMC)
Low Voltage Directive (LVD)
RoHS Directive

What is a Responsible Person under GPSR?

A Responsible Person is a newer role introduced under the General Product Safety Regulation (EU) 2023/988, which came into full effect in December 2024. This position serves as the primary contact point for market surveillance authorities regarding product safety matters across a much broader range of products than traditional CE marking.
Unlike Authorized Representatives who focus on specific product categories, the Responsible Person role applies to virtually all products made available on the EU market, including:

New products
Used products
Repaired products
Reconditioned products
Consumer goods that don’t require CE marking

The Responsible Person must proactively assess product risks and ensure proper labelling and information provision. They also coordinate with authorities during investigations and support any necessary recall actions or consumer notifications.

How do you know which role your business needs?

Your choice depends on the specific products you sell and which EU regulations apply to them. Products subject to harmonised legislation typically require an Authorized Representative, whilst the broader product safety obligations under GPSR require a Responsible Person.
Many businesses actually need both roles because their products fall under multiple regulatory frameworks. For example, electronic devices need an Authorized Representative for EMC and LVD compliance, plus a Responsible Person for general product safety under GPSR.
Consider these factors when determining your needs:

Does your product require CE marking? If yes, you likely need an Authorized Representative
Do you sell any products to EU consumers? If yes, you need a Responsible Person under GPSR
Are you selling through online marketplaces? They typically require GPSR compliance
Do you have an established place of business in the EU? If not, representation is mandatory

What are the main responsibilities of each role?

Both roles share certain core functions but operate under different regulatory frameworks with distinct obligations. Understanding these differences helps you ensure proper compliance across all applicable regulations.

Responsibility Area	Authorized Representative	Responsible Person (GPSR)
Documentation Management	Holds Declaration of Conformity and technical files for CE marking	Maintains product safety documentation
Authority Cooperation	Responds to requests from notified bodies and market surveillance	Primary contact for market surveillance authorities on safety matters
Risk Assessment	Supports compliance verification activities	Proactively assesses product risks and potential hazards
Information Requirements	Ensures proper CE marking and conformity information	Ensures proper product labelling and information provision
Incident Response	Supports non-conformity investigations	Coordinates recall actions and consumer notifications

The Authorized Representative focuses on demonstrating compliance with specific technical requirements, whilst the Responsible Person takes a broader approach to overall product safety throughout the product lifecycle.

Making the right choice for your EU market strategy

Selecting the appropriate representation depends on your product portfolio, target markets, and regulatory obligations. Many businesses benefit from working with European authorized representative services that can handle both roles, providing comprehensive coverage under multiple regulatory frameworks.
Key considerations for your decision include:

Product scope: Authorized Representatives operate under specific harmonised legislation with established technical requirements
Regulatory coverage: Responsible Persons address broader safety obligations under GPSR that apply to virtually all products on the EU market
Service integration: Many providers offer combined services for both roles

Consider partnering with a service provider that understands both frameworks and can assess your specific needs. This approach ensures you maintain compliant market access whilst avoiding the complexity of managing multiple relationships for different regulatory requirements.
Remember that non-compliance can result in significant fines, forced product removal, or complete exclusion from the EU market. At EARP, we provide comprehensive coverage under both frameworks, ensuring your products meet all applicable requirements for safe and uninterrupted EU market access.
If you are looking for support or to learn more, contact our team of experts today