What role do distributors play in GPSR and how is it different from the importer role?
Under the General Product Safety Regulation (EU) 2023/988 (GPSR), distributors and importers are both “economic operators,” but they sit at different points in the supply chain and have different legal duties. A distributor mainly checks what is already on the product and keeps it safe while handling it, while an importer takes on additional responsibility for products entering the EU from outside. Below are the practical GPSR duties and when a Responsible Person is still required.
What does a distributor have to do under the GPSR?
A distributor is an economic operator in the supply chain, other than the manufacturer or importer, that makes a product available on the EU market. Under the GPSR, distributors must act with due care and should not supply products they know, or should suspect, are unsafe or non-compliant. Their role is largely verification, traceability support, and cooperation after placement on the market.
- Verify that required product information is present before making it available, such as product identification (type, batch, serial), manufacturer details, and, where applicable, importer details.
- Check that instructions and safety information are included in the language(s) required for the Member State of sale.
- Ensure any additional labels do not obscure mandatory markings or information.
- Make sure storage and transport conditions do not jeopardize product safety or required markings.
- Cooperate with market surveillance authorities, including providing traceability information and supporting checks.
- Handle complaints and information about accidents, pass them to the relevant operator, and support corrective actions.
- Take action when needed, including stopping sales, withdrawal, and supporting recall activities.
How is the importer role different from the distributor role under the GPSR?
An importer is the EU-established economic operator that places a product from a third country on the EU market. Unlike a distributor, the importer is the first EU gatekeeper for non-EU goods and has stronger pre-market obligations. In practice, importers must do more than “check the label”; they must have confidence that the manufacturer has met applicable product safety requirements.
| Topic | Distributor | Importer |
|---|---|---|
| When the role applies | Makes a product available after it has already been placed on the market | First EU operator placing a non-EU product on the EU market |
| Core focus | Due care, verification, safe handling, cooperation | Manufacturer compliance assurance and EU entry responsibility |
| Documentation readiness | Supports traceability and authority requests | Must help ensure technical documentation can be made available to authorities on request |
| Marking and contact details | Checks required information is present and not obscured | Must ensure required identification and importer contact details are correctly provided where required |
| Response to risks | Stops supply and supports corrective actions | Initiates and supports corrective actions with heightened responsibility as the EU entry operator |
When do you need a GPSR responsible person if you already have an importer or distributor?
You need an EU-based Responsible Person for GPSR-covered products when the manufacturer is not established in the EU, unless another eligible EU economic operator already fills that function. The GPSR sets a hierarchy of who can be the Responsible Person: an EU manufacturer, an importer, an authorised representative with a written mandate, a fulfilment service provider (in certain cases), or another EU-established entity designated in writing where allowed.
Having a distributor does not automatically satisfy the Responsible Person requirement, because distributors are not automatically the designated Responsible Person under the GPSR structure. An importer can often serve as the Responsible Person, but many importers do not want the operational burden of making documentation available and interacting with authorities. Marketplace checks also tend to require clear, consistent identification of the Responsible Person and aligned product identifiers across labels, instructions, and listings.
Also note the separate framework in the Market Surveillance Regulation (EU) 2019/1020 (MSR): the Responsible Person must, among other tasks, inform the manufacturer if there is reason to believe a product presents a risk, and must be able to provide documentation to authorities on request.
How does EARP help with GPSR distributor and importer compliance?
We help non-EU manufacturers, brands, and sellers meet GPSR market access requirements by providing independent EU Authorized Representative and Responsible Person support, with practical processes that fit distributor, importer, and marketplace workflows.
- Acting as your EU Responsible Person and, where appropriate, authorised representative under a written mandate
- Checking the presence and completeness of required product safety documentation and key identifiers for consistency
- Secure technical documentation storage and rapid provision to authorities upon request
- Liaison support with EU market surveillance authorities and structured handling of safety questions and corrective action coordination
See our services to confirm the right setup for your supply chain, or contact us to discuss your products and the fastest path to GPSR compliance.
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