--- title: "We have no EU responsible person" description: "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. There are four possibilities: a manufacturer in the Union, an importer, an authorised representative with a written mandate, or, failing those, a fulfilment service provider for the products it handles. Without an importer, a non-EU manufacturer can appoint an authorised representative." type: "problem" url: "https://www.conphora.com/solutions/problem/no-eu-responsible-person/" markdown: "https://www.conphora.com/solutions/problem/no-eu-responsible-person.md" locale: "en" language: "en" updated: "2026-10-05" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/eli/reg/2023/988/oj" tags: ["GPSR", "roles-responsibilities"] license: "Free to quote with attribution and a link to the page" --- # We have no 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. There are four possibilities: a manufacturer in the Union, an importer, an authorised representative with a written mandate, or, failing those, a fulfilment service provider for the products it handles. Without an importer, a non-EU manufacturer can appoint an authorised representative. ## Why this happens The rule is short. Under Article 16(1) of the General Product Safety Regulation (EU) 2023/988 a product covered by the regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020. [1] Article 4(2) of Regulation (EU) 2019/1020 lists who that operator can be: a manufacturer established in the Union; an importer, where the manufacturer is not established in the Union; an authorised representative who has a written mandate from the manufacturer; or a fulfilment service provider established in the Union with respect to the products it handles, where no other of these operators is established in the Union. A marketplace provider that also offers fulfilment services can be a fulfilment service provider for those products; the GPSR says this is assessed case by case (recital 46). [2] The tasks are in Article 4(3): verifying that the declaration of conformity and the technical documentation have been drawn up and keeping them at the disposal of the authorities, providing information and documentation on a reasoned request, informing the authorities when the operator has reason to believe that a product presents a risk, and cooperating with them on corrective action. [2] The GPSR adds regular checks of its own: that the product matches its technical documentation and carries the identification, contact details and instructions required by Article 9(5), (6) and (7) (Article 16(2)). [1] ## How to solve it 1. **Check whether an importer already fills the role** If a company established in the Union places your product on the market, it is the importer, and the importer is the responsible person. 2. **Otherwise appoint an authorised representative** Choose a company established in the Union and give it a written mandate that designates it to perform the tasks of the responsible person on your behalf. 3. **Hand over what the role needs** The responsible person verifies that the documentation has been drawn up and keeps it at the disposal of the authorities, so it needs the technical documentation and, where one exists, the declaration of conformity. 4. **Agree how you are told about problems** The responsible person informs the authorities when it has reason to believe a product presents a risk, and cooperates with them. It needs a working line to you for complaints and test results. 5. **Put the name and addresses on the product and in every offer** On the product, its packaging, the parcel or an accompanying document, and in the online offer. ## What you need to show - **The written mandate** — The manufacturer (Regulation (EU) 2019/1020 Article 4(2)(c); GPSR Article 10(1)) - **Technical documentation and declaration of conformity** — The manufacturer, kept available by the responsible person (Regulation (EU) 2019/1020 Article 4(3)(a)) - **Name and contact details, including the postal and electronic address** — On the product, its packaging, the parcel or an accompanying document (GPSR Article 16(3); Regulation (EU) 2019/1020 Article 4(4)) ## If you do nothing - **The product may not be placed on the market** — A product covered by the regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for it (GPSR Article 16(1)). - **Online offers are incomplete** — Where the manufacturer is not established in the Union, the offer must indicate the name, postal and electronic address of the responsible person (GPSR Article 19(b)). - **Penalties under national law** — Each Member State sets its own penalties for infringements of the regulation (GPSR Article 44). ## Questions ### Can a letterbox address do the job? The operator must be established in the Union and able to perform the tasks: keep the documentation available, provide it to authorities on request, inform them of risks and cooperate on corrective action. An authorised representative must have the appropriate means to fulfil its tasks (Regulation (EU) 2019/1020, Article 5(3)). ### Is the authorised representative liable for the product? Under the GPSR it performs the tasks in its mandate, and the manufacturer keeps the manufacturer's obligations. Liability for damage is a separate matter: for products placed on the market or put into service from 9 December 2026 whose manufacturer is outside the Union, Directive (EU) 2024/2853 makes the authorised representative liable alongside the importer, as national law transposing it provides. ### Do we need one per country? No. One economic operator established in the Union is enough for the Union market. ### Does the role exist for CE-marked products as well? Yes. Regulation (EU) 2019/1020 created it for products under the harmonisation legislation listed in its Article 4(5), and the GPSR applies it to the products it covers. ## Regulations involved GPSR ## Sources 1. [Regulation (EU) 2023/988 on general product safety](https://eur-lex.europa.eu/eli/reg/2023/988/oj) — EUR-Lex, 2026-09-21 2. [Regulation (EU) 2019/1020 on market surveillance and compliance of products](https://eur-lex.europa.eu/eli/reg/2019/1020/oj) — EUR-Lex, 2026-09-21 3. [Directive (EU) 2024/2853 on liability for defective products](https://eur-lex.europa.eu/eli/dir/2024/2853/oj) — EUR-Lex, 2026-09-28