EU Authorized Representative & Responsible Person Services
EARP Services
At EARP, we provide independent Authorized Representative (AR) and Responsible Person (RP) services under the General Product Safety Regulation (GPSR) (EU) 2023/988 and Union harmonized legislation (CE Marking regulations and directives). Our role ensures that your company meets the legal requirement to appoint an EU-based economic operator for products sold within the EU. We act as your formal EU contact point for regulatory matters and market surveillance, helping you maintain safe and uninterrupted market access.
Comprehensive services that take the burden off of you
Our AR and RP services are tailored to fulfill the responsibilities outlined under the GPSR and the Market Surveillance Regulation (EU) 2019/1020. These include:
- Holding and making available the Declaration of Conformity and technical documentation
- Verifying the presence and completeness of required product safety documents
- Permit the use of EARP’s name, address, and electronic contact details on product labeling, packaging, or accompanying materials.
- Cooperating with EU market surveillance authorities during inspections, investigations, or safety events associated to your product
- Notifying you and authorities of serious product risks where required
- Supporting recall actions or consumer notifications initiated by the manufacturer
- Providing templates for essential documentation to support you with meeting the regulatory obligations under the GPSR.
Seamless Guidance
We provide a structured and professional onboarding experience, designed to help you meet your obligations under the GPSR quickly and efficiently. Once your onboarding is complete, you may list EARP as your EU Representative on your product labeling and documentation.
Comprehensive Representation
While our core service offering focuses on GPSR representation, we can also act as the Authorized Representative under other applicable legislation where required, including EMC, LVD and RoHS. If your products fall under multiple frameworks, we’ll confirm where EARP can support you.
Products We Support
Our services are designed specifically for non-food consumer and industrial products covered under the GPSR and other EU product safety legislation. This includes but not limited to:
Unpacking AR vs. RP
Authorized Representative
If you are a manufacturer based outside the European Union and intend to place products on the EU market, the GPSR requires you to designate an economic operator established in the EU. This includes products sold online through platforms like Amazon or eBay, fulfilled via warehouses or third-party logistics providers, or distributed by EU-based partners. If none of these economic operators assumes the necessary compliance responsibilities, you must formally appoint an AR as the EU-based economic operator that acts as your responsible person.
Responsible Person
The GPSR requires that a EU-based RP is designated to handle specific compliance tasks. The RP ensures that regulatory obligations are met after the product is placed on the market. An AR can be chosen to act as the RP; if so, it performs both the GPSR Article 10 tasks and the Article 16 “responsible person” duties. EARP fulfills both roles where necessary, providing an all-in-one solution for compliance with GPSR obligations.
So, which one do you need?
If your product covered under the GPSR, you need to assign a RP according to Article 16. When an AR is appointed, they typically also act as the RP streamlining compliance and serving as a single point of contact for EU market surveillance authorities. Contact our team for more information on the roles, obligations and decision criteria.
The benefits of an independent Authorized Representative
Unlike importers or distributors, EARP operates independently with dedicated focus on your regulatory compliance. Working with us provides:
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EU Authorized Representative and Responsible Person FAQ
Familiarize yourself with key facts around EU Authorized Representative and Responsible Person requirements.
If you are a non-EU manufacturer selling products into the European Union, you are required under the General Product Safety Regulation (GPSR) (EU) 2023/988 to appoint an Authorized Representative (AR) based in the EU to take on the role of the Responsible Person unless another economic operator in the supply chain (such as an importer or fulfillment service provider) assumes that role. The AR is responsible for several critical compliance functions, including: Holding and providing access to the Declaration of Conformity where applicable and technical (safety) documentation; Cooperating with market surveillance authorities during investigations or inspections Notifying authorities of serious risks or accidents involving your products; Supporting recalls and corrective actions when necessary; Retaining essential product documentation for 10 years after the product has been placed on the EU market, and more. The GPSR sets horizontal AR obligations in Article 10; sector laws may add AR tasks for specific product categories. Manufacturers may also designate the AR as the responsible person under Article 16. This role is not just administrative, it is a regulatory obligation intended to ensure that national (competent) surveillance authorities can quickly reach a responsible and knowledgeable party when product safety concerns arise. In other words, the AR bridges the regulatory gap between a non-EU manufacturer and EU enforcement bodies. Without an appointed AR (or other qualifying economic operator), your products are not legally permitted to be marketed in the EU.
An AR must be a natural or legal person established in the European Union. This can be a subsidiary, an importer, a distributor, or an independent third-party service provider like EARP. However, appointing a commercial partner such as a distributor can lead to conflicts of interest and operational challenges. Independent ARs like EARP offer neutrality, continuity, and regulatory expertise without commercial entanglements.
In addition to the AR, the GPSR refers to a ‘Responsible Person’ in the context of product safety responsibilities and obligations. This term is also used in the Market Surveillance Regulation (EU) 2019/1020 to describe the party ensuring availability of documentation and cooperation with authorities. Moreover, the RP must verify compliance with technical documentation, labeling, and traceability requirements. These duties go beyond those listed in the Market Surveillance Regulation and apply to all GPSR products. The RP must be established in the EU. Therefore, the RP can be either the manufacturer itself, the importer, the authorized representative or the fulfillment service provider, provided the entity in question is established in the Union and accepts and fulfills the relevant safety obligations. Therefore, although any economic operator can act as the RP, if you are a non-EU based manufacturer and have no importer/distributor in the EU, you must appoint an AR who will fulfill the RP role. When EARP is designated as your AR, we also fulfill these RP responsibilities, offering a single point of accountability for GPSR compliance.
An economic operator is a legal entity involved in making available and placing a product on the EU market. This includes the manufacturer, importer, distributor, fulfillment service provider, and the Authorized Representative. Each has different responsibilities under EU law, and it’s critical to ensure that at least one economic operator in the EU is taking on the required compliance role.
The legal manufacturer is the company that designs and markets the product under its name or brand and assumes responsibility for its conformity with applicable EU regulations. For non-EU companies, the obligation to designate an EU economic operator is non-negotiable under the GPSR. This makes the appointment of an AR essential when there is no EU-based importer or logistics provider assuming the role.
An importer is any natural or legal person established within the Union who places a product from outside the EU on the Union-market. They carry legal liability for compliance, and their name must appear on the label. A distributor is any natural or legal person further down the supply chain who makes the product available on the market without changing its properties. The Authorized Representative is formally mandated by the manufacturer to act on their behalf in relation to regulatory activities. If there is no physical presence in the EU, meaning no EU-based manufacturer, importer, or distributor that is taking on these regulatory responsibilities, the manufacturer must appoint an EU-based AR. In such a case, an AR is typically not commercially involved.
Yes, the GPSR states that products may not be placed on the Union market if no EU-based operator is taking responsibility for the tasks set out under Article 4(3) of the MSR. If no importer or EU entity assumes full regulatory responsibility, you must appoint an Authorized Representative that assumes the role of Responsible Person. Distance sales are captured by this requirement; the seller cannot circumvent these obligations because transactions occur online. This therefore also applies to online-only and fulfillment models.
Market surveillance refers to the activities carried out by national authorities in the EU to verify that products on the market comply with applicable safety and compliance laws. Authorities may contact the AR or RP to request technical documentation, initiate recalls, or investigate complaints and incidents. Appointing an AR like EARP ensures these obligations are met professionally and without delay. Market surveillance refers to the activities carried out by national authorities in the EU to verify that products on the market comply with applicable safety and compliance laws. Authorities may contact the AR or RP to request technical documentation, initiate recalls, or investigate complaints and incidents. Appointing an AR like EARP ensures these obligations are met professionally and without delay.
Many manufacturers and importers assume that CE marking alone guarantees access to the EU market or that Amazon or the distributor handles compliance. In reality, non-EU manufacturers must designate a responsible economic operator for GPSR compliance. Failing to do so can lead to listing removals, customs hold, and fines. EARP was created to address this gap with clarity and compliance expertise.
EARP acts as your independent EU Authorized Representative and fulfills the Responsible Person role under the GPSR. If you’re a non-EU manufacturer preparing to sell products in Europe, our team can help you meet all your representation requirements.EARP acts as your independent EU Authorized Representative and fulfills the Responsible Person role under the GPSR. If you’re a non-EU manufacturer preparing to sell products in Europe, our team can help you meet all your representation requirements.
