Who can be the EU responsible person
Under GPSR Article 16, a product may only be placed on the EU market if there is an economic operator established in the EU responsible for it. That can be:
- the manufacturer, if it is established in the EU;
- an importer;
- an authorised representative with a written mandate from the manufacturer;
- a fulfilment service provider, where none of the above is established in the EU.
Sellers often call it the “EU RP” or “EC REP”. The role comes with duties — keeping the technical documentation available, cooperating with market surveillance authorities and reporting risks — so make sure the person or company has actually accepted it before printing its name.
What to print
Article 16(3) asks for the responsible person's name, registered trade name or trade mark and contact details, including the postal and electronic address. The label generator prints it in one line under the manufacturer:
Manufacturer: Shenzhen Example Co., Ltd., 1 Example Rd, Shenzhen 518000, China, [email protected]
EU Responsible Person: Example EU Rep GmbH, Musterstraße 1, 10115 Berlin, Germany, [email protected]Use “Field names on the label” to print the labels in German, French, Italian, Spanish, Dutch, Polish or Swedish, or the short form “EU RP”.
Where the label goes
The law allows the product itself, its packaging, the parcel or an accompanying document. Most sellers put a sticker on the retail packaging; for FBA, the label must be on each unit before it reaches the fulfilment centre. The same details belong in your online listing (Article 19) — copy them from listing text.
Step-by-step guide
- The EU responsible person on your label — Who can be the EU responsible person under GPSR Art. 16 and Regulation (EU) 2019/1020 Art. 4, what details go on the label (name, postal an…
Frequently asked questions
Is “EC REP” the same as the EU responsible person?
Sellers use the terms loosely. “EC REP” comes from medical-device labelling, where it marks the authorised representative. Under GPSR the role is the economic operator of Article 16. On the label, the words “EU Responsible Person” (or a translation) with name and contact details make the meaning clear.
Can my Amazon FBA warehouse be the responsible person?
Only a fulfilment service provider that has agreed to take on the role can be — storing your goods alone does not make it your responsible person. Check in writing.
Do I need a responsible person if I sell from China to EU consumers directly?
Yes. Article 16 applies to products sold to consumers in the EU, including distance sales from outside the EU.
Can the label be in English only?
The names and addresses are just names and addresses; warnings and safety information must be in the language of the country of sale. Many sellers print field names in English and warnings in each market's language.
Legal references: Regulation (EU) 2023/988 (GPSR) — the text on EUR-Lex is authoritative. Page last reviewed 2026-11-06. General information, not legal advice.