The EU responsible person on your label

Why the EU needs a responsible person

GPSR Art. 16(1) says a product may only be placed on the EU market if there is an economic operator established in the EU responsible for the tasks the regulation sets for it. For products under EU harmonisation laws — toys, electrical equipment, machinery and others — Regulation (EU) 2019/1020 Art. 4 sets the same rule. Authorities contact this operator when a product is unsafe, when they need documents, or when a recall is needed.

Who can be the responsible person

In this order, depending on how the product reaches the EU:

1. a manufacturer established in the EU;
2. an importer, where the manufacturer is not established in the EU;
3. an authorised representative — a person or company in the EU with a written mandate from the manufacturer;
4. a fulfilment service provider established in the EU, where none of the above exists.

A company in the United Kingdom, Switzerland, Norway or Turkey is not established in the EU. A fulfilment service provider or warehouse is only your responsible person if it has actually agreed to take on that role — storing your goods is not enough.

What to print

GPSR Art. 16(3): the responsible person's name, registered trade name or registered trade mark, and contact details including the postal and electronic address, on the product or its packaging, the parcel or an accompanying document. In practice:

EU Responsible Person: Example EU Representative GmbH Beispielstraße 10, 10115 Berlin, Germany [email protected]

• A full postal address with the country — not a P.O. box only, not just a website.
• An email address or website contact form that is actually answered.
• The label wording “EU Responsible Person”, “EU RP” or the equivalent in the local language — the generator offers field names in nine languages.

“EC REP”, “EU RP”, authorised representative

“EC REP” with its box symbol comes from the medical devices rules, where it marks the authorised representative. On ordinary consumer products, “EU Responsible Person” (or “EU RP”) describes the GPSR role more clearly. An authorised representative is one of the operators who can be the responsible person — the label shows the company in that role, whatever its title.

Responsible person, manufacturer and importer on one label

• Manufacturer outside the EU, sold directly to EU consumers (marketplace, own shop): manufacturer + EU responsible person (usually an authorised representative or a fulfilment provider that has agreed to the role).
• Manufacturer outside the EU, goods imported by an EU company: manufacturer + importer; the importer is often also the responsible person, and then one entry is enough.
• Manufacturer in the EU: the manufacturer alone; tick The manufacturer is established in the EU in the generator.

Use the same names and addresses on the label, in your marketplace settings and in your documents: listing text for Amazon, eBay and Etsy.

Checking your responsible person

Before you print thousands of labels, ask your responsible person for a written confirmation that they act in that role for your products, which name and address they want on the label, and which documents (technical documentation, test reports, instructions) they need from you. Their tasks under the law include keeping documents available to authorities and cooperating with them on risks and corrective actions — they will need your product information to do that.