EU authorised representative and GPSR: who needs one

Your listing has a field for an EU contact, and the law put it there.

Since December 13, 2024, the General Product Safety Regulation has required online offers of products made outside the EU to name the responsible person in the EU. Marketplaces must set up their listing pages so you can enter it.

Two regulations, two roles

Two EU laws ask for an economic operator in the EU:

• Regulation (EU) 2019/1020 asks for one for products under certain EU product laws. An authorised representative is one way to fill the role.
• The General Product Safety Regulation (Regulation (EU) 2023/988, or GPSR) calls the same role the responsible person. It borrows the list of who can fill the role, and the tasks, from Regulation 2019/1020.

Two laws that ask for an economic operator in the EU

	Regulation (EU) 2019/1020, Article 4	Regulation (EU) 2023/988 (GPSR), Article 16
What it says	Toys, electrical and radio equipment and other products under the laws listed in Article 4 may be placed on the EU market only if an economic operator based in the EU is responsible for them. It keeps the declaration of conformity for the authorities.	A product under the General Product Safety Regulation may be placed on the EU market only if an economic operator based in the EU is responsible for set compliance tasks. Its name and contact details go on the product, packaging, parcel or a document with it.
Who can fill the role	A manufacturer in the EU, an importer, an authorised representative with a written mandate, or a fulfillment service provider in the EU where none of the others is	The same list, taken from Regulation 2019/1020
Tasks	Check the declaration of conformity and technical documentation exist, keep the declaration ready, answer authorities’ requests, report risks and cooperate on corrective action	The same tasks, plus regular checks, where the risks call for it, that the product matches its technical documentation and carries the identification, contact details and instructions Article 9 requires
On the label	Name, registered trade name or registered trade mark, and contact details including a postal address	The same, plus an electronic address
Applies from	July 16, 2021	December 13, 2024

The five-question checker shows which of these rules your own answers trigger.

CE-marked goods: Regulation 2019/1020

Article 4 of Regulation 2019/1020 applies only to products under a list of EU laws in its paragraph 5. The list covers toys, electrical and radio equipment and machinery, among others. Since the new batteries regulation, it names batteries too.

The European Commission says the regulation as a whole covers more than 70 EU laws on non-food products.

The EU’s Your Europe portal says CE marking is required only for products covered by EU rules that ask for it, and if no such rule covers your product, you must not use the mark.

An authorised representative needs your written mandate. Article 5 says it performs the tasks the mandate sets and shows a copy to the authorities when they ask.

Consumer products: Regulation 2023/988

The GPSR covers items meant for consumers or likely to be used by them, with some exclusions such as food and medicines. It has applied since December 13, 2024.

A product it covers may be placed on the EU market only if an economic operator based in the EU is responsible for it. The European Commission’s Safety Gate says:

• every product the GPSR covers must have a responsible person in the EU
• that person’s contact details must appear on the product

So a product with no CE mark can still need an EU contact.

What goes on the label

Two sets of details go on a consumer product, and the GPSR sets both.

What the GPSR asks for on the product and in the listing

	What it must show	Where
Responsible person	Name, registered trade name or registered trade mark, and contact details, including postal and electronic address (Article 16)	On the product, its packaging, the parcel or an accompanying document
Manufacturer	Name, registered trade name or registered trade mark, postal and electronic address (Article 9)	On the product, or on its packaging or an accompanying document where that is not possible
Product identifier	A type, batch or serial number, or another element that identifies the product (Article 9)	On the product, easy to see and read, or on the packaging or a document where its size or nature does not allow it
Online listing	Manufacturer’s details, the responsible person’s details if the manufacturer is outside the EU, a picture and the product type, and any warnings or safety information (Article 19)	In the offer, clearly and visibly

Where a product needs instructions and safety information to be used safely, they must come in a language consumers can easily understand, as the EU country where you sell decides.

Check who the manufacturer is before you print labels. Your Europe says you count as the manufacturer if you have a product made for you and sell it under your own name or brand.

So a private-label seller who has goods made in China and sells them under its own brand counts as the manufacturer.

What the role does not cover

The representative does not make your product compliant. Your Europe says the manufacturer must make sure a product meets every EU requirement that applies, and must affix the CE mark.

Under the GPSR, the manufacturer carries out the risk analysis and draws up the technical documentation. The representative checks that it exists and keeps it ready.

The role does not move your own duties onto someone else either. Article 4 sets its tasks without prejudice to the obligations you already have under the product laws, and the Safety Gate says a business with several roles in the chain meets the obligations of each one.

It covers the EU only. GOV.UK says products placed on the market in Great Britain must meet GB rules, even if they were sold in an EU country before. What you need to do depends on the type of goods.

Placing a product on the GB market from outside the UK brings importer responsibilities.

For anything beyond the tasks in Article 4, such as who pays if a product causes harm, ask a lawyer.