We have no EU responsible person

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. 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)).^[2][1]