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Marketplace and retailer demands Online seller · Manufacturer 5 min read

A marketplace asks for our EU responsible person

A product covered by the General Product Safety Regulation may only be placed on the EU market when an EU-established economic operator is responsible for it. For a non-EU manufacturer, the name, postal and electronic address of that person must appear in every online offer, so the marketplace asks. The role can be filled by an EU manufacturer, importer, authorised representative or, failing those, a fulfilment service provider.

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Reviewed 5 October 2026 by the Conphora compliance team · Not legal advice

Why this happens

Article 16(1) of the General Product Safety Regulation (EU) 2023/988 states that a product covered by the regulation shall not be placed on the market unless an economic operator established in the Union is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020. The marketplace does not set this rule. It collects the information because it has to display it.[1]

Who can be that operator is listed in Article 4(2) of Regulation (EU) 2019/1020: a manufacturer established in the Union; an importer, where the manufacturer is not established in the Union; an authorised representative with a written mandate from the manufacturer; or a fulfilment service provider established in the Union for the products it handles, where none of the other three is established in the Union.[2]

The information then has to be visible. Where the manufacturer is not established in the Union, an online offer must indicate the name, postal and electronic address of the responsible person (Article 19(b)), and marketplaces must build their interface so that traders can provide it (Article 22(9) and (10)).[1]

How to solve it

  1. Find out whether you already have one

    If the manufacturer is established in the Union, the manufacturer is the responsible person. If an importer in the Union places the product on the market, the importer is. Many sellers have the role filled without having named it.

    Regulation guidesKnow-how Free Open
  2. If nobody fills the role, appoint an authorised representative

    The manufacturer gives a written mandate to a company established in the Union. The mandate must cover the tasks of the responsible person.

  3. Give the responsible person the documents

    The responsible person keeps the documentation at the disposal of the authorities and hands it over on request, so it must hold the technical documentation and, where one exists, the declaration of conformity.

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  4. Put the name and both addresses on the product and in the offer

    Name, postal address and electronic address go on the product, its packaging, the parcel or an accompanying document, and into the listing.

Work through the steps in the platform with your own product.

What you need to show

DocumentWhere it comes fromLegal ground
Name, postal and electronic address of the responsible personThe economic operator that fills the roleGPSR Articles 16(1), 16(3) and 19(b)
The written mandateThe manufacturer, when an authorised representative is appointedGPSR Article 10(1); Regulation (EU) 2019/1020 Article 4(2)(c)
Technical documentation and declaration of conformityThe manufacturer, held at the disposal of the responsible personRegulation (EU) 2019/1020 Article 4(3)(a)

If you do nothing

The product may not be placed on the market

Without an economic operator established in the Union who is responsible for it, a product covered by the regulation shall not be placed on the market (GPSR Article 16(1)).[1]

The offer is incomplete

An online offer must show the responsible person where the manufacturer is not established in the Union (GPSR Article 19(b)).[1]

Penalties under national law

Each Member State sets its own penalties for infringements of the regulation (GPSR Article 44).[1]

Questions about this problem

Can the marketplace be our responsible person?

Not as a marketplace. A fulfilment service provider established in the Union can fill the role for the products it handles, but only where no manufacturer, importer or authorised representative is established in the Union. A marketplace provider that also offers fulfilment services can be a fulfilment service provider for those products, assessed case by case (GPSR recital 46).

Is a postal address enough?

No. The offer must show the name, the postal address and the electronic address.

Is this the same person as under the CE marking rules?

It is the same role. Regulation (EU) 2019/1020 created it for products under the harmonisation acts listed in its Article 4(5), and the GPSR applies the same article to the products it covers.

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Sources

  1. Regulation (EU) 2023/988 on general product safety EUR-Lex · accessed 21 September 2026
  2. Regulation (EU) 2019/1020 on market surveillance and compliance of products EUR-Lex · accessed 21 September 2026

About this page

Reviewer
Conphora compliance team
Reviewed
5 October 2026
Cite this page
Conphora (2026). A marketplace asks for our EU responsible person. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/marketplace-responsible-person/
Reviewed
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