GPSR: Who Is Your EU Responsible Person?

The role has to sit inside the EU

Under the EU General Product Safety Regulation, a product sold to an EU consumer needs a Responsible Person established inside the EU. Their name and address have to appear on the product or its packaging, and the role carries real legal liability for safety documentation and for cooperating with market-surveillance authorities.

That geography requirement is the part sellers most often miss. It is not a document that can be produced on request by whoever happens to be handling the goods. It is a legal role held by an entity with an EU establishment, and it cannot be satisfied by a supplier, a factory or a fulfilment agent operating from outside the union.

Why your fulfilment agent is not it

We are not your EU Responsible Person, and we would treat any China-based agent who claims to be as a warning sign rather than a convenience. An agent that misrepresents this is not saving you a step; it is leaving you exposed at the exact moment a marketplace or an authority asks who the Responsible Person is.

What a fulfilment partner can legitimately do is the practical work around the requirement. In our case that means helping you apply for the documentation a product needs, and helping you find a third party willing to act as the Responsible Person. A fee usually applies for that service, charged by the party taking the role rather than absorbed by us. Once the arrangement exists, fulfilment continues as normal, including printing the required details on labels and packaging.

What to sort out, and in what order

• Confirm whether the products you sell fall in scope for the markets you actually ship to.
• Identify who will hold the role. An EU-established importer, distributor, or a specialist service that offers it commercially.
• Assemble the technical documentation and safety evidence that the role holder will need to stand behind.
• Agree how the name and address will physically appear on the product or packaging, and who prints it.
• Check what your marketplaces require as proof, since platform rules and enforcement timing can differ from the underlying regulation.

Raise it before you scale, not after

The expensive version of this problem is discovering it through a listing suspension rather than through planning. A product that is selling well is the worst moment to pause for a compliance arrangement, because the fix involves a third party, documentation and a packaging change, none of which happen in a day.

It is also worth separating two questions that often get merged. Whether a product can be shipped is a logistics question. Whether it can lawfully be sold to an EU consumer is a compliance question. A parcel that moves without incident is not evidence that the second question has been answered.

The practical takeaway

The Responsible Person must be established in the EU, and no amount of goodwill from a China-based partner substitutes for that. Decide who holds the role, budget for it, get the documentation together, and make the labelling change before volume makes it disruptive. Tell your fulfilment partner the products and the markets, and expect a plain answer about what applies rather than reassurance.