Sell in Europe · The EU responsible person
The EU responsible person: who you need in the EU, and why
The requirement most non-EU sellers discover from a marketplace form or a customs hold. Here is the role, the four ways to fill it and the one that usually fits.
What the role is
Regulation (EU) 2019/1020 provides that a product under the acts listed in its Article 4 — among others the Low Voltage, Radio Equipment, RoHS, Toy Safety and PPE acts — may be placed on the market only if an economic operator established in the Union is responsible for the tasks in that article. The GPSR extends the requirement to all consumer products in its scope. The name and contact details of this operator must appear on the product, its packaging, the parcel or an accompanying document.
Who can fill it
The regulation lists the options in order. The first that exists in the EU is the responsible person.
| Option | What it is | When it fits you |
|---|---|---|
| EU manufacturer | Only if you produce inside the EU. | Not an option for a company established outside the EU. |
| Importer | The EU company that first places your product on the market. It takes on the duties — and many importers refuse products without a complete file. | Your distributor or customer becomes the importer; you supply the compliance file. |
| Authorised representative | An EU company you mandate in writing to hold the technical file and speak to the authorities on your behalf. | The usual answer for direct sellers and marketplace sellers. In Managed, Conphora arranges it through a partner firm. |
| Fulfilment service provider | Only when none of the above exists in the EU — the warehouse becomes responsible for the products it handles. | Rarely what you want. |
What the responsible person must do
- Verify that the EU declaration of conformity and the technical documentation have been drawn up, and keep them or make them available to market surveillance authorities.
- Provide information and documentation demonstrating conformity on a reasoned request.
- Inform the authorities where the product presents a risk, and cooperate in ensuring corrective action.
- Under the GPSR: regularly check that the product matches its technical documentation and carries the required identification and safety information, and document those checks.
What goes on the product and the listing
On the product
The responsible person's name and contact details on the product, its packaging, the parcel or an accompanying document — next to the manufacturer's and, where there is one, the importer's details.
On the online offer
Every online or distance offer must show the manufacturer's name and address, the responsible person's details where the manufacturer is outside the EU, the product identification and any warning or safety information required, in the language determined by the Member State.
On the marketplace
Marketplaces must design their interfaces so that traders can supply this information and consumers see it on the listing; Amazon, Zalando and the others ask for it at listing time.
Three ways a non-EU seller fills the role
- 1
An EU importer
Your distributor or first customer in the EU places the product on the market and becomes the importer. It takes on the duties and puts its name on the product — and will want your complete file first. Fits sellers with one partner per country or region.
- 2
An appointed authorised representative
An EU-established company you mandate in writing to hold the technical file and speak to the authorities. You keep selling under your own brand, on marketplaces and from your own shop. The usual answer for direct sellers. In the Managed service Conphora arranges it through a partner firm.
- 3
A fulfilment service provider, as a last resort
Only where no manufacturer, importer or authorised representative exists in the EU does the warehouse that stores and dispatches your goods become responsible for them. Rarely what either side wants.
What it costs to get wrong
No listing
Marketplaces cannot show a listing without the responsible person's details, and can suspend traders that repeatedly offer non-compliant products.
Customs holds
Products entering the EU are controlled at the border under Regulation (EU) 2019/1020; a missing responsible person is a reason to hold a shipment.
Safety Gate
Dangerous products are notified through the Safety Gate rapid alert system and published; authorities can order withdrawal, recall and the removal of listings within two working days.
Managed service
Need an authorised representative? We arrange it — through a partner
In the Managed service the responsible-person mandate is signed with an EU-established partner firm, in your name and clearly labelled as theirs; their address goes on your labels and they hold the file on your behalf. Conphora runs the compliance work around it: the rules map, the technical file, the labels, the registrations and the channel onboarding. Conphora is not itself an authorised representative, not a law firm and not a notified body.
How Conphora helps
- Free to read
Regulation pages, the glossary, this guide and the free compliance checker. No account.
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Reviewed 10 September 2026 by Conphora compliance team
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