EU Responsible Person and Authorised Representative guidance under GPSR and Regulation 2019/1020 for non-EU manufacturers and online sellers.
Under the GPSR, an applicable product may not be placed on the EU market without an EU-established responsible economic operator. That role may be an EU manufacturer, importer, authorised representative or, in defined circumstances, a fulfilment service provider. The correct role depends on the product law and supply chain.
Reviewed against official sources: 2026-07-23
Who can be the responsible economic operator?
A manufacturer established in the EU.
Where the manufacturer is outside the EU, the EU importer may carry the relevant role.
An EU authorised representative with a written mandate covering the required tasks.
In a supply chain without the above operators, an EU fulfilment service provider may be the relevant economic operator in defined circumstances.
What changes for online offers?
The GPSR treats an online offer targeted at EU consumers as making the product available on the market.
Online product offers must display manufacturer information and, for a non-EU manufacturer, the name and postal and electronic address of the EU responsible person.
Responsible-person information must also appear on the product, packaging, parcel or accompanying document as permitted by the applicable rules.
The responsible person must be able to cooperate with market surveillance, maintain or provide compliance information and respond to safety matters.
How JWhelp supports the process
Identify the GPSR, CE harmonisation and sector-specific rules applicable to the product.
Map responsibility between manufacturer, importer, authorised representative and fulfilment provider.
Review labels, instructions, online displays and the technical-file checklist.
The mandate should define tasks, records, accident notification, cooperation and termination in writing.
Decision table
| Role | When it may apply | Core point |
|---|---|---|
| EU manufacturer | Manufacturer established in the EU | Direct manufacturer obligations |
| Importer | EU operator places non-EU product on market | Verify compliance and retain records |
| Authorised representative | Written mandate from manufacturer | Only mandated and statutory tasks |
| Fulfilment provider | Defined cases with no other EU operator | May become the last responsible operator |
Frequently asked questions
Does every product require a separately appointed representative?
Not necessarily. First identify the product legislation and whether an EU manufacturer, importer or other qualifying operator already fulfils the role.
Can a UK company be the EU Responsible Person?
A UK establishment alone is generally not an establishment in the EU. The responsible operator for the EU market must satisfy the EU establishment requirement.
Does appointing a representative transfer every manufacturer obligation?
No. Manufacturer obligations do not simply disappear. The representative’s tasks follow the applicable law and written mandate.
Must online listings show the responsible person?
The GPSR sets information requirements for online and other distance offers, including the EU responsible person’s name and postal and electronic address where the manufacturer is outside the EU.
Official sources
The following primary sources were used for factual review. Rules and administrative practice can change; the actual transaction and responsible entity must still be assessed.