EU Authorised Representative: which of the three roles you are being asked for

In the Regulation’s words, the EU Responsible Person is an economic operatorArt. 3(13)the manufacturer, the authorised representative, the importer, the distributor, the fulfilment service provider or any other natural or legal person who is subject to obligations in relation to the manufacture of products or making them available on the market ...Click the term for the full definition, and without one your product may not be sold in the EUArt. 3(7)the first making available of a product on the Union marketClick the term for the full definition at all (GPSR Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.).

An “EU Authorised Representative” is one of the four kinds of company that can be your responsible person. It is not a second thing to buy. A “GDPR representative” has nothing to do with product safety. The three sit side by side below, so you can tell which one a quote is selling you.

How the three roles compare, side by side

The third row comes from the data-protection law, Regulation (EU) 2016/679Regulation (EU) 2016/679, General Data Protection RegulationThe whole regulationClick opens the law on the EU Publications Office., not from GPSR. Its trigger is Art. 3(2)Regulation (EU) 2016/679, General Data Protection RegulationArticle 3, paragraph 2Click opens the article on EUR-Lex.: offering goods or services to people in the EU, or monitoring their behaviour there. The representative’s duty is in Art. 27Regulation (EU) 2016/679, General Data Protection RegulationArticle 27Click opens the article on EUR-Lex.:

“Where Article 3(2) applies, the controller or the processor shall designate in writing a representative in the Union.”

“The representative shall be established in one of the Member States where the data subjects […] are.”

Where the two product-safety words come from:

• GPSR never defines “responsible person”. Article 3 has 30 definitions in its current text, two of them added by Regulation (EU) 2024/2748, and that phrase is not one of them. The role comes from Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.: your product may not be sold in the EU unless an EU-based company is responsible for the tasks in Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office..
• “Authorised representative” is defined, in Art. 3(9)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 9Click opens the article on EUR-Lex.: a person or company based in the EU that holds a written mandate from the manufacturerArt. 3(8)any natural or legal person who manufactures a product or has a product designed or manufactured, and markets that product under that person’s name or trademarkClick the term for the full definition to do named tasks for it under GPSR.

So one is a thing your product must have. The other is a person your manufacturer may appoint. They are not two names for one purchase.

Why an authorised representative is one way to be the responsible person

GPSR does not list who can be the responsible person itself. Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. points to another law, Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office., and takes its Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex. and (3). That Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex. says only four kinds of EU-based company can hold the role:

1. an EU manufacturerArt. 3(8)any natural or legal person who manufactures a product or has a product designed or manufactured, and markets that product under that person’s name or trademarkClick the term for the full definition;
2. an importerArt. 3(10)any natural or legal person established within the Union who places a product from a third country on the Union marketClick the term for the full definition, where the manufacturer is not based in the EU;
3. an authorised representative holding a written mandate from the manufacturer;
4. an EU fulfilment service providerArt. 3(12)any natural or legal person offering, in the course of commercial activity, at least two of the following services: warehousing, packaging, addressing and dispatching, without having ownership of the products involved ...Click the term for the full definition, and only where none of the other three exists in the Union.

The full list, and when the fourth kind counts, is on the EU Responsible Person.

Three things follow from that list. Each one saves you money.

An authorised representative is one of the four, not an extra. Hiring one is one way of getting your responsible person under Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.. It is not a second duty on top. If a provider quotes you “Authorised Representative” and “EU Responsible Person” as two services for the same product, you are being charged twice for one thing. Pay for one.

If someone in your chain is already one of the four, you buy nothing. Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. only asks that such a company exists for your product. An EU importerArt. 3(10)any natural or legal person established within the Union who places a product from a third country on the Union marketClick the term for the full definition who brings your goods in is number two on the list. An EU subsidiary of yours that makes or imports the product is number one or two.

Only the manufacturer can appoint an authorised representative, and it does not have to. A manufacturer may appoint one by a written mandate (Art. 10(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 10, paragraph 1Click opens the article on EUR-Lex.). Nothing in Art. 10Regulation (EU) 2023/988, General Product Safety RegulationArticle 10Click opens the article on EUR-Lex. forces it. What is forced is having a responsible person under Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.. Appointing an authorised representative is one way to get there.

What the marketplaces actually call it

The three big platforms ask for the same role under three different names. These are the platforms’ own rules, not law, and they change without notice.

What each platform says, in its own words:

• Amazon, GPSR announcement in the Seller Forums: “Responsible Person: It’s mandatory to have a Responsible Person established within the EU for your non-food products. Make sure to label your products with their contact information in one of the EU’s official languages.”
• Etsy, help page on adding an economic operator: it frames the shop-level field first as a Digital Services Act requirement, and only then says that GPSR may need more added to individual listings. On GPSR, its GPSR help page writes: “If you’re a manufacturer based outside the EU, you may appoint a Responsible Person (such as an Authorized Representative) for your products in the EU.” The words in brackets say it: an authorised representative is one way to have a responsible person.
• eBay, help page: it defines the role as “a type of economic operator which is established in the EU”, and adds: “You can add up to five EU responsible persons.”

A blocked listing means the Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. responsible person, whatever the field is called. Art. 22(9)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9Click opens the article on EUR-Lex. is the least a marketplace must ask for; a platform can ask for more under its own contract with you. The page that walks each marketplace’s fields screen by screen is GPSR marketplace requirements.

What happens if you do nothing

If you buy the wrong role, you pay twice: once for a service that does not answer the demand, and again for the demand that is still open.

Without a responsible person your product may not be sold in the EU at all (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.). If your manufacturerArt. 3(8)any natural or legal person who manufactures a product or has a product designed or manufactured, and markets that product under that person’s name or trademarkClick the term for the full definition is outside the EU, every online listing must show the responsible person’s name, postal address and email, clearly and visibly (Art. 19(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (b)Click opens the article on EUR-Lex.), and the marketplace must give you a field for exactly that (Art. 22(9)-(10)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraphs 9 to 10Click opens the article on EUR-Lex.). The role also has a live duty: if the manufacturer is outside the EU and the responsible person learns of an accident, it must make sure the authorities are told (Art. 20(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 20, paragraph 4Click opens the article on EUR-Lex.). A GDPR representative does none of this. An authorised representative does it only if it holds the mandate and is your responsible person under Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex..

What hits you first comes from the platform, not the law:

• eBay, help page: if you do not comply “your listings may not be visible or purchasable to buyers in the EU and Northern Ireland”. Visibility is restored when the required information is provided.
• Amazon, forum announcement: “Non-compliant listings risk removal and ineligibility for flash sales.”
• Etsy, help page: no penalty for the empty field itself, and an opt-out: “You can opt out of selling your products to GPSR countries.” Its Seller Handbook adds that once an authority notifies Etsy that a product is non-compliant, Etsy may remove the listing or suspend the account.

GPSR sets no fine of its own. Each EU country sets its own penalties, and the law only says they must be “effective, proportionate and dissuasive” (Art. 44Regulation (EU) 2023/988, General Product Safety RegulationArticle 44Click opens the article on EUR-Lex.). So the number depends on the country. Each country’s fines are on GPSR fines.

What the same words mean in other EU laws

“Authorised representative” is not only a GPSR word. Other EU laws have their own, with their own tasks. A mandate written for one law does not cover another.

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office., has two of them:

• Its authorised representative is defined in almost the same words as GPSR’s: a person based in the EU with a written mandate from the manufacturer for specified tasks under that Regulation (PPWR Art. 3(19)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 19Click opens the article on EUR-Lex.). The tasks are different: keep the EU declaration of conformity and the technical documentation for five years for single-use packaging and ten for reusable, answer authorities’ requests, and hand over documents within ten days of a request (PPWR Art. 17(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 17, paragraph 2Click opens the article on EUR-Lex.).
• Its “authorised representative for the extended producer responsibility” (PPWR Art. 3(20)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 20Click opens the article on EUR-Lex.) is per country. A producer covered by PPWR Art. 45(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 3Click opens the article on EUR-Lex. must appoint one, by written mandate, in each EU country where it first makes packaging available, other than the EU country where it is established.

The claim that you need a representative in every EU country you ship to is not true for GPSR. GPSR Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. asks for one EU-based company, and one is enough. The per-country rule exists only for packaging, under PPWR. The packaging rules are on the EU packaging law, PPWR.

The same word also appears in the EU’s product laws for specific sectors, and there it means different things:

Where the sector law makes the representative optional, the EU-based operator is still required, by Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., because all those acts are on its Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex. list. The GPSR responsible person is that same Art. 4Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4Click opens the article on EUR-Lex. operator applied to products outside the sector laws, plus the Art. 16(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex. regular checks.

A tax representative for VAT is a different role again, set out in fiscal representative.

What you can skip

What the law leaves open

• Whether one provider may hold more than one of these roles at once. Nothing in GPSR forbids it, and no guidance or court has settled it. This is a genuine edge case. Meanwhile, give each role its own written mandate under its own law: a mandate written for one law does not cover another.