The EU Responsible Person: who can be one, and what they owe

The EU Responsible Person is the one GPSR duty a business outside the EU cannot do in-house, cannot automate, and cannot postpone. It is also the duty most often sold wrongly, because the vendors of the service have no reason to explain the parts that would narrow what you need to buy.

This page reads the actual text. Every claim carries its article. Where we have not verified something, it says so instead of smoothing it over.

The requirement, in the Regulation’s own words

A product covered by GPSR 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 Art. 4(3) of Regulation (EU) 2019/1020 in respect of that product (Art. 16(1)).

Read that sentence carefully, because two things in it decide everything else.

First, it is a condition on the product, not a licence you buy. Nothing says you must “appoint” anybody. It says the product may not be placed on the market unless such an operator exists. If an EU-established operator in your chain already occupies the role, the condition is already met and you buy nothing.

Second, the tasks are not defined in GPSR at all. They live in a different Regulation, and Art. 16(1) imports them by reference: Art. 4(2) and (3) of Regulation (EU) 2019/1020 apply to GPSR products, with the words “Union harmonisation legislation” in Art. 4(3) read as “this Regulation”.

That imported Art. 4(2) is the part most competitor guides leave vague, and it is the part that decides whether you can be your own responsible person. You cannot.

Who is allowed to be it: a closed list of four

For the purposes of Art. 4, the economic operator referred to in Art. 4(1) means any of the following (Reg. (EU) 2019/1020, Art. 4(2)):

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 designating them to perform the Art. 4(3) tasks on the manufacturer’s behalf;
a fulfilment service provider established in the Union with respect to the products it handles, where no other economic operator as mentioned in points (a), (b) and (c) is established in the Union.

Four boxes, and being outside the EU excludes you from all of them. If you are the manufacturer but not EU-established, box 1 is shut. If you sell direct to consumers with no EU importer, box 2 is empty. That leaves box 3, which is what is sold as an “EU Responsible Person” service, and box 4, which is a fallback and only a fallback.

Point 4 is worth reading twice if you use an EU fulfilment centre. A fulfilment service provider qualifies only where nobody in boxes 1 to 3 is established in the Union, and only for the products it actually handles. It is not a first choice you can elect; it is what the text falls back to when the other three are absent.

What the responsible person must actually do

The responsible person's tasks. The first four rows are the Art. 4(3) tasks imported into GPSR by Art. 16(1); the rest are GPSR's own additions.
Role	What it must do	Source
Conformity documentation	Where the applicable legislation provides for a declaration of conformity or performance and technical documentation, verify these were drawn up, keep the declaration at the disposal of market surveillance authorities for the period that legislation requires, and ensure the technical documentation can be made available on request.	Reg. 2019/1020 Art. 4(3)(a)
Answer reasoned requests	On a reasoned request from a market surveillance authority, provide all information and documentation needed to demonstrate the conformity of the product, in a language that authority can easily understand.	Reg. 2019/1020 Art. 4(3)(b)
Report suspected risk	When having reason to believe the product presents a risk, inform the market surveillance authorities.	Reg. 2019/1020 Art. 4(3)(c)
Cooperate on corrective action	Cooperate with market surveillance authorities, including making sure immediate corrective action is taken to remedy non-compliance or, failing that, to mitigate the risk - when required to do so by the authorities or on its own initiative.	Reg. 2019/1020 Art. 4(3)(d)
Regular checks (GPSR-only addition)	Regularly check, where appropriate with regard to the possible risks, that the product complies with the technical documentation under Art. 9(2) and with the requirements of Art. 9(5), (6) and (7). On request by market surveillance authorities, provide documented evidence of the checks performed.	GPSR Art. 16(2)
Be named on the product	Name, registered trade name or registered trade mark, and contact details including the postal and electronic address, indicated on the product or on its packaging, the parcel or an accompanying document.	GPSR Art. 16(3)
Accident notification	Where the manufacturer is not established in the Union, the responsible person who has knowledge of an accident must ensure the notification is made - through the Safety Business Gateway, to the competent authorities of the Member State where the accident occurred, without undue delay.	GPSR Art. 20(1), 20(4)
Traceability, as an economic operator	A responsible person is an economic operator (Art. 3(13)), so the general cooperation duty reaches it: on request, supply a full description of the risk and any corrective measure, and identify who supplied the product and who it was supplied to. Presentable for 10 years for the risk and corrective-measure information, 6 years for the supply-chain information.	GPSR Art. 15(2)-(5)

Scroll the table sideways to see the source column.

Two details in that table earn their keep.

The regular checks in Art. 16(2) are GPSR’s own invention. They do not exist in Regulation (EU) 2019/1020 Art. 4. GPSR adds them, ties them to Art. 9(2) and Art. 9(5) to (7), and then requires documented evidence of them on request. That is recurring work on a real product, not a mailbox.

And the address requirement differs between the two Regulations. GPSR Art. 16(3) requires the postal and electronic address. Regulation (EU) 2019/1020 Art. 4(4) requires contact details “including the postal address”. If your product sits under the 2019/1020 route rather than the GPSR one, the labelling duty you are meeting is the 2019/1020 one.

Where the name has to appear

Three separate places, three separate articles:

On the product, its packaging, the parcel or an accompanying document (Art. 16(3)).
In the offer, where the manufacturer is not established in the Union: the name, postal and electronic address of the responsible person, clearly and visibly, alongside the manufacturer’s details, product identification including a picture of the product, and any warning or safety information in a language easily understood by consumers as determined by the Member State where the product is made available (Art. 19).
In the marketplace’s interface fields, which the marketplace is required to design and organise so that traders can supply exactly that information for each product (Art. 22(9)-(10)).

The trigger for all of it is targeting, not shipping: an offer is deemed to make the product available on the EU market if it is targeted at consumers in the Union, and it is treated as targeted if the operator directs its activities to one or more Member States by any means (Art. 4).

What you can skip

You can skip this

If your product is covered by sector-specific Union harmonisation legislation, GPSR Article 16 does not apply to it. Art. 2(1)(b) switches off Chapter III Section 1 for products subject to specific requirements under Union harmonisation legislation, and Chapter III Section 1 is Articles 9 to 18 - Section 2 begins at Article 19. Article 16 sits inside it. So do not buy a GPSR responsible person for a toy, a radio product, machinery or PPE, and do not build a GPSR Art. 9(2) technical file for one.

This is a redirect, not a free pass, and the redirect has a precise address. Regulation (EU) 2019/1020 Art. 4(1) imposes the same “must exist” requirement by its own route, but only for the instruments listed in its Art. 4(5) - which include toys (Directive 2009/48/EC), machinery (2006/42/EC), PPE (Reg. 2016/425), gas appliances (Reg. 2016/426), construction products (Reg. 305/2011), low voltage (2014/35/EU), EMC (2014/30/EU), radio equipment (2014/53/EU), RoHS (2011/65/EU), pressure equipment (2014/68/EU) and others. For those, the role is the same closed list of four and the same Art. 4(3) tasks - you are just not buying it under GPSR, and the extra Art. 16(2) regular checks do not come with it. Note also that Art. 2(1)(b) switches off Section 1 only: Article 19 sits in Section 2 and still applies, so a harmonised product sold at distance must still show responsible-person details in the offer.

Three roles, routinely sold as if they were one bundle. They are not the same thing and they do not come from the same law.

Three distinct EU representation roles. Different instruments, different triggers, different work.
Role	What it must do	Source
Responsible Person	The economic operator established in the Union without whom a product may not be placed on the market. Triggered by placing a covered product on the EU market. Can be an EU manufacturer, an importer, an authorised representative, or - only as a fallback - an EU fulfilment service provider.	GPSR Art. 16(1); Reg. 2019/1020 Art. 4(1)-(2)
Authorised Representative	A person established in the Union holding a written mandate from the manufacturer to act on its behalf on specified tasks. It is one of the four ways to fill the responsible-person role, not a synonym for it. The mandate must cover the Art. 4(3) tasks, and a copy must be provided to market surveillance authorities on request, in a Union language they determine.	GPSR Art. 3(9); Reg. 2019/1020 Art. 3(12), Art. 4(2)(c), Art. 5
GDPR Article 27 representative	A representative in the Union designated in writing by a controller or processor not established in the Union, where GDPR reaches them under Art. 3(2). Addressed by supervisory authorities and data subjects on all issues related to processing. Must be established in a Member State where the relevant data subjects are. Nothing to do with product safety.	GDPR Art. 3(2), Art. 27(1), 27(3), 27(4)

Scroll the table sideways to see the source column.

Two points that matter commercially.

An authorised representative is a way of being the responsible person, not an alternative to it. Art. 4(2)(c) puts the AR inside the list. If a provider offers “AR services” and “Responsible Person services” as two separate purchases for the same product under the same legislation, ask which provision makes them two things.

The GDPR Article 27 representative is a genuinely separate obligation, with a different trigger and its own exemption. It bites on processing personal data of data subjects in the Union under Art. 3(2), and Art. 27(2)(a) exempts processing that is occasional, does not include special-category or criminal-offence data on a large scale, and is unlikely to result in a risk to the rights and freedoms of natural persons. It also carries a location rule the product roles do not: the representative must be established in one of the Member States where the data subjects are (Art. 27(3)), while a product-safety responsible person may be established anywhere in the Union.

What actually drives the price

We are not going to quote figures we have not verified, and neither should anyone else. But the shape of the pricing reads straight off the duties, and it explains why quotes for the same job differ by orders of magnitude.

Per product, or per portfolio. The requirement in Art. 16(1) attaches to a product. The Art. 16(2) checks are per product too, against that product’s technical documentation. A provider pricing per SKU and a provider pricing per company are selling different quantities of the same obligation, and neither is wrong on the face of the text.

Per year, because the duties recur. Art. 16(2) says “regularly check” and requires documented evidence on request. Art. 15(4) and (5) require information to be presentable for 10 years and 6 years respectively. Art. 20(4) can fire at any time. This is a standing obligation with a long tail, not a one-off registration, so a price shaped like a filing fee is pricing something else.

Per country, which the text does not require. See the skip callout above. Ask what provision a per-Member-State line item is charging for.

Risk carried, which is the real variable. The responsible person answers reasoned requests from authorities in a language the authority chooses (Art. 4(3)(b)), must inform authorities when it has reason to believe the product presents a risk (Art. 4(3)(c)), and must make sure corrective action is taken (Art. 4(3)(d)). A provider that reads your technical file and performs documented checks is doing more work, and carrying more exposure, than one that forwards letters. The floor of this market is a name and an address; the ceiling is a party that will actually stand behind Art. 4(3)(d). Both can truthfully call themselves an EU Responsible Person, which is why the spread is so wide.

Switching cost, which is built into the labelling. The name and address go on the product, its packaging, the parcel or an accompanying document (Art. 16(3)) and into every offer (Art. 19). Changing provider means changing what is printed and what is published. Price the exit before you price the entry.

What we have not verified

Stated plainly, so you know the edges of this page:

What each sector regime requires instead. We verified from the text of Reg. (EU) 2019/1020 Art. 4(5) which instruments that Article covers. We did not read those instruments themselves, nor the regimes outside that list - cosmetics and medical devices among them - so this page does not tell you what representation role they impose or what it is called there.
Whether one provider may lawfully hold the GPSR responsible-person role and the GDPR Art. 27 role at the same time. We read both provisions and found no text forbidding it, but the absence of a prohibition in the two articles we read is not a verified answer.
National penalty figures and national enforcement practice. GPSR leaves penalties to Member States. We have not read any national implementing law, so this page repeats no figures.
What individual marketplaces require contractually. Art. 22(9) sets the floor for the fields a marketplace must offer. A marketplace can and does demand more than the Regulation, and that is a contract question, not a GPSR question.
How “regularly” in Art. 16(2) is interpreted in practice. The text says regularly, and “where appropriate with regard to the possible risks related to a product”. It sets no interval. Anyone quoting a fixed frequency as a legal requirement is quoting guidance or their own service level, not the Regulation.

Who can do this for you

Nobody is listed here yet.When this page lists providers, it will say exactly which job each one does.We would rather show an empty box than fill it with names we have not checked.

Disclosure, in advance. When providers are listed here, each entry will show whether we earn from it. Any entry that has paid for its placement will be labelled as paid placement in the entry itself - not in a footnote, and not on another page. Listings will never change what the guide above says you do or do not have to do.