EU Responsible Person: who can be yours, and what it costs

Marketplaces call that operator your EU Responsible Person: a company based in the EU that carries responsibility for your product before it is sold in the EUArt. 3(7)the first making available of a product on the Union marketClick the term for the full definition (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.).

Who can be yours: a closed list of four

GPSR does not list them itself. Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. points at another law and takes Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex. and (3) of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. into GPSR, with the words “Union harmonisation legislation” in Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. read as “this Regulation”. That imported Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex. is the part that decides whether you can be your own responsible person. You cannot.

For the purposes of Art. 4Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4Click opens the article on EUR-Lex., the economic operator referred to in Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex. means any of the following:

1. “a manufacturer established in the Union”;
2. “an importer, where the manufacturer is not established in the Union”;
3. an authorised representative who has 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 designating them to perform the Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. tasks on the manufacturer’s behalf;
4. “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 based in the EU, 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.

Read point 4 slowly if you use an EU fulfilment centre. A 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 qualifies only where nobody in boxes 1 to 3 is based in the EU, 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.

Responsible Person, Authorised Representative and GDPR representative are not three purchases. An authorised representative is one of the four ways to hold the responsible-person role (Art. 4(2)(c)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2, point (c)Click opens the article on EUR-Lex.), not an alternative to it. The GDPR Art. 27Regulation (EU) 2016/679, General Data Protection RegulationArticle 27Click opens the article on EUR-Lex. representative is a separate obligation under a different Regulation with its own trigger; when you need one is on GDPR Article 27. Which of the three a marketplace or a customer is actually asking you for is EU Responsible Person vs Authorised Representative.

Why it is a condition on the product, not a licence you buy

The whole requirement is one sentence, and these are the law’s own words: a product “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)Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. in respect to that product” (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.).

Nothing in it says you must “appoint” anybody. It says the product may not be placed on the marketArt. 3(7)the first making available of a product on the Union marketClick the term for the full definition unless such an operator exists. If an operator based in the EU already occupies the role in your chain, the condition is already met and you buy nothing. What every other role owes is GPSR requirements, by role.

When the requirement reaches you

All three of these have to hold:

1. GPSR covers the product. Art. 2(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 2Click opens the article on EUR-Lex. takes whole categories back out, and where a product is subject to specific requirements under Union harmonisation legislation, Chapter III Section 1 - where Art. 16Regulation (EU) 2023/988, General Product Safety RegulationArticle 16Click opens the article on EUR-Lex. sits - does not apply to it at all (Art. 2(1)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1, point (b)Click opens the article on EUR-Lex.). That test belongs to the page on whether GPSR applies to you. Settle it there first; the skip section below says what to do if the answer is harmonisation legislation.
2. The product is placed or made available on the EU market. An offer online or at distance counts 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 EU countries by any means (Art. 4Regulation (EU) 2023/988, General Product Safety RegulationArticle 4Click opens the article on EUR-Lex.). Shipping is not the trigger. Targeting is.
3. Nobody based in the EU already holds the role. If 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 entity, 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 or an existing authorised representative already fills one of the four boxes above, Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. is satisfied and there is nothing to buy.

If all three hold, the role has to be filled before the product is placed on the market. If any of them fails, this is not your obligation and you can stop here.

What changes if your product has its own EU law

Which law makes you name an EU company depends on the product. GPSR Art. 16Regulation (EU) 2023/988, General Product Safety RegulationArticle 16Click opens the article on EUR-Lex. is only one of them: it drops out for any product subject to specific requirements under Union harmonisation legislationArt. 3(27)Union legislation listed in Annex I to Regulation (EU) 2019/1020 and any other Union legislation harmonising the conditions for the marketing of products to which that Regulation appliesClick the term for the full definition (Art. 2(1)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1, point (b)Click opens the article on EUR-Lex.).

The Commission’s guidelines name childcare articles, gymnastic equipment and furniture as products GPSR covers in full, because no other EU law sets specific requirements for them (C/2025/6233, section 2.2). The guidelines never mention REACH. Our reading of the furniture example: REACH chemical limits reach furniture like every other article, yet furniture stays in the first row, so a law that touches almost every product does not by itself move yours out of it. The same reading is why the clothing row says to act as if GPSR applies.

In the first two rows the online offer works the same way. Where the manufacturer is outside the EU, the offer names the EU company, and the law names both kinds: “the responsible person within the meaning of Article 16(1) of this Regulation or Article 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.” (Art. 19(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (b)Click opens the article on EUR-Lex.). The marketplace field takes the same one (Art. 22(9)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9, point (b)Click opens the article on EUR-Lex.).

Amazon, eBay and Etsy ask for that field on EU listings whatever law covers your product. That is their policy, quoted under “If you do nothing”. Enter the company from the table: for a toy or an electrical product, that is the Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex. operator.

What your responsible person has to do

The regular checks in Art. 16(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex. are GPSR’s own invention. They do not exist in Art. 4Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4Click 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.. GPSR adds them, ties them to Art. 9(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 2Click opens the article on EUR-Lex. and Art. 9(5)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 5Click opens the article on EUR-Lex. to (7), and then requires documented evidence of them on request. That is recurring work on a real product, not a mailbox.

The address requirement differs between the two Regulations. GPSR Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex. requires the postal and electronic address. Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. Art. 4(4)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 4Click opens the article on EUR-Lex. 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:

1. On the product, its packaging, the parcel or an accompanying document (Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.).
2. In the offer, where the manufacturer is not based in the EU: 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 EU country where the product is made available (Art. 19(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (b)Click opens the article on EUR-Lex.).
3. In the marketplace’s interface fields. An online marketplaceArt. 3(14)a provider of an intermediary service using an online interface which allows consumers to conclude distance contracts with traders for the sale of productsClick the term for the full definition has to design and organise its interface so that traders can supply exactly that information for each product offered, and so that it is displayed or otherwise made easily accessible to consumers on the listing (Art. 22(9)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9, point (b)Click opens the article on EUR-Lex., Art. 22(10)(a)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 10, point (a)Click opens the article on EUR-Lex.). Supplying it is your part, not theirs. What each marketplace calls the field and where it hides it is on GPSR marketplace requirements. 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 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 EU countries by any means (Art. 4Regulation (EU) 2023/988, General Product Safety RegulationArticle 4Click opens the article on EUR-Lex.).

What happens if you do nothing

The first consequence is in Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. itself, and it is not a fine: without 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 based in the EU responsible for the Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. tasks, the product may not be placed on the market. Every later sale of it is the sale of a product that should not have been there.

The second arrives through the channel rather than the regulator, and it arrives fast, because the responsible person is a form field.

• 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.” On what happens without it: “Non-compliant listings risk removal and ineligibility for flash sales.”
• eBay, Seller Center GPSR page: business sellers are told that if the manufacturer “isn’t located in the EU or NI, you’ll have to indicate an EU-based Responsible Person or entity, along with their name and contact details”, and that without the required information “your listings may not be visible or purchasable to buyers in the EU and Northern Ireland”.
• Etsy, help page: it restates the rule in the Regulation’s own shape - “products can’t be placed on the EU market unless they have an EU-based economic operator responsible for key safety tasks” - and offers an opt-out from EEA sales. 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.

Those are marketplace policies, not law, and they change without notice.

The third is national. GPSR sets no figure itself: each EU country lays down the rules on penalties applicable to infringements, and the Regulation requires only that they be effective, proportionate and dissuasive (Art. 44Regulation (EU) 2023/988, General Product Safety RegulationArticle 44Click opens the article on EUR-Lex.). What each country actually sets is on GPSR fines.

What you can skip

How each vendor’s price grows with the catalogue. Read on each vendor’s own page on 3 October 2026, in the vendor’s currency and the vendor’s units. The unit differs from row to row, so the rows are not comparable line by line. Alphabetical, not ranked.

The other vendors publish one price or one starting price and no ladder; they are in the table that follows.

What the entry price leaves out. Each line is what that vendor’s page says, read on 3 October 2026.

• The technical documents. The manufacturer draws up the technical documentation and keeps it for 10 years (Art. 9(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 2Click opens the article on EUR-Lex., Art. 9(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 3Click opens the article on EUR-Lex.). The responsible person verifies that it exists and can be produced (Art. 4(3)(a)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3, point (a)Click opens the article on EUR-Lex.). A price that leaves out writing the file is therefore normal. Westwood Sourcing’s EUR 150 a year covers its name and address, storage of the technical files and handling of authority communication, and the page says the documents themselves are not in the base service. Its shop page lists the technical file at EUR 180; one labelling check is included, and further ones are EUR 80. Eldris says its appointment does not include your declarations of conformity or technical files.
• Checking what you hand over. The Commission’s guidelines describe the regular checks as comparing the product with its technical documentation and checking the identification number, the manufacturer’s details and the instructions and safety information (Art. 16(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex., C/2025/6233, section 3.2). 24hour-AR’s EUR 1,150 plan has no verification of technical documentation, labels or declarations of conformity. Its EUR 2,450 plan adds it, for up to 20 regulated products. Comply EU lists label checks in its service description. EU Presence’s entry plan lists risk assessment and safety documentation, and Euverify’s lists risk assessment templates and a declaration of conformity.
• Corrective action and recalls. The operator has to make sure the necessary corrective action is taken when an authority asks, or on its own initiative when it has reason to believe the product presents a risk (Art. 4(3)(d)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3, point (d)Click opens the article on EUR-Lex.). 24hour-AR lists recall support and compliance actions after an authority request as paid services in its two cheapest plans, and as included from its EUR 3,450 plan. EU Presence lists full recall and crisis response only in its USD 2,497 plan.
• Authority work counted in units. EU Presence’s entry plan includes one market-surveillance response a year, and the plans above it list unlimited responses. EU Compliance Partner’s entry rate includes 2 hours of support for market surveillance requests.
• Risk category. Euverify’s plans cover low-risk and GPSR product families. CE or UKCA-marked products are added per product per year: GBP 50 for moderate risk such as consumer electronics, lighting and home appliances, and GBP 100 for high risk such as toys, machinery, protective equipment and radio products. AuraDPP’s entry plan covers textiles, furniture, stationery and general goods, its EUR 149 a month plan adds electronics, toys, sports equipment and tools, and its EUR 249 a month plan is the one that lists cosmetics, jewellery and chemicals. EaseCert charges EUR 400 for clothing, footwear and accessories, EUR 500 for electrical products, toys, or household goods and furniture, and EUR 600 for protective equipment.
• A second region. Euverify’s two cheapest plans cover one region, with a second at GBP 200 a year, and both regions are included from GBP 1,490 a year. Eldris counts the UK as another GBP 195 market.

First year, renewal and what lapses. Eldris’s own example for one market and up to 20 SKUs is GBP 434.40 in year one and GBP 239.40 a year after. EU Compliance Partner’s FAQ names USD 300 for the first year for clients already using its other services and USD 500 after. 24hour-AR takes 5 percent off a two-year commitment, 10 percent off three years and 20 percent off five. Eldris says an appointment and its certificate stay active while the monthly plan runs. If an appointment lapses, every unit placed on the market after that day fails Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex., because placing is judged unit by unit (C/2025/6233, section 2.1). Shipping from outside the EU, that is every new order. Your labels and listings also go on naming a company that no longer holds the role (Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex., Art. 19(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (b)Click opens the article on EUR-Lex.).

A price per country. Eldris charges GBP 195 for each EU country it appoints in. Its own example is four countries (Germany, France, Italy and Spain) with up to 50 SKUs: GBP 741 once, then GBP 39.95 a month. GPSR asks for one operator established anywhere in the Union; question 6 in how to compare a quote says what a per-country line has to name.

One name, separate mandates. EU Presence’s pricing page says each of its representative products is a separate appointment with its own addendum. It prices its GDPR representative at USD 127 a month and its GPSR representative from USD 597 a year. A GDPR representative does not fill the product-safety role, and buying one does not unblock a listing.

Who sells it, and what they charge

The free route first. Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. is a condition, not a purchase. Before comparing anybody, check whether 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 based in the EU already in your chain fills one of the four boxes: a subsidiary that manufactures in the Union, an EU importer, meaning the business that places your goods on the EU market and not merely the customs broker that declares them (importer of record), a distributorArt. 3(11)any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a product available on the marketClick the term for the full definition that is in fact importing, or an EU business already holding a written mandate for the Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. tasks. If one does, the requirement is met at no cost, and what is left to do is the labelling (Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.) and the offer text (Art. 19(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (b)Click opens the article on EUR-Lex.).

What the market charges. Alphabetical, not ranked. “Entry price” is the cheapest tier each vendor published, which is rarely the tier a real catalogue needs.

Every figure is what that vendor publishes on its own page, in that vendor’s currency. A published price is not a quote, and only a signed contract binds anybody. ConformityPoint and Obelis publish no price at all.

The REP27 note. Its own site carries two prices for the same thing. The pricing table bundles “Responsible person under Article 16 GPSR” into the top Multi plan at EUR 890/year, while a Solutions section on the same page advertises “Responsible person… Article 16 Regulation (EU) 2023/988Regulation (EU) 2023/988, General Product Safety RegulationThe whole regulationClick opens the law on the EU Publications Office.” at “from EUR 290/year”. The page’s own text says the role “is included in our Multi plan”, and the two cheaper plans (EUR 290 and EUR 490) list no Art. 16Regulation (EU) 2023/988, General Product Safety RegulationArticle 16Click opens the article on EUR-Lex. role, so the EUR 290 figure matches no plan that includes it. On 3 October 2026 the page listed renewal prices of EUR 240, EUR 390 and EUR 690 a year; the only plan in its table that includes the Art. 16Regulation (EU) 2023/988, General Product Safety RegulationArticle 16Click opens the article on EUR-Lex. role renews at EUR 690 after EUR 890 in year one. Only the figure written into a signed contract is the one that binds.

Names in the same search results that sell something else. EUProof’s pricing page lists document generation and storage - risk assessment, technical file, declaration of conformity, label text - and no responsible-person address. SafeCart sells Safety Gate monitoring and says in its own words that it “does not replace the legal obligations of economic operators under EU law”. ProductIP sells a compliance-management platform. None of the three offers a responsible-person service on its pages. A document generator is not an EU address, and an EU address is what Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. asks for.

How to compare a quote

Six questions separate the quotes, and each one reads off an article.

1. What is the unit, and is it yours? The requirement in Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. attaches to a product. The Art. 16(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex. checks are per product too, against that product’s technical documentation. Vendors price per SKU, per product type, per product family or per company, and those words are not interchangeable: five product families and five SKUs are very different catalogues. Convert every quote into your own SKU count before comparing anything.

2. Does the price include the Art. 16(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex. checks, or only the address? Art. 16(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex. requires a regular check that the product still matches its technical documentation and still meets Art. 9(5)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 5Click opens the article on EUR-Lex., (6) and (7), plus documented evidence of those checks on request. A provider that reads your technical file and produces that evidence is doing recurring work; a provider that supplies a name and an address is not. Both can truthfully call themselves an EU Responsible Person, which is the single biggest reason the prices diverge. What that file has to contain is in GPSR technical documentation, or, for a CE-marked product, CE technical file.

3. Who answers the authority, and in which language? Art. 4(3)(b)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3, point (b)Click opens the article on EUR-Lex. requires the information to be given “in a language which can be easily understood by that authority” - the authority’s language, not yours. A reasoned request can arrive in Italian on a Friday. The contract must say whether answering it in the authority’s language is included, and how many responses a year are covered.

4. Who carries Art. 4(3)(d)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3, point (d)Click opens the article on EUR-Lex.? That is the duty to make sure the immediate, necessary corrective action is taken, or the risk mitigated. It is the task on the list that can cost real money, and it is the one a mailbox service cannot perform. The contract must say, in writing, what the provider does when an authority orders a withdrawal.

5. What is the exit? The name and address go on the product, its packaging, the parcel or an accompanying document (Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.) and into every distance offer (Art. 19(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (b)Click opens the article on EUR-Lex.). Changing provider means changing what is printed and what is published, across every listing and every carton already made. The contract must name who owns the technical file, how it is exported and what the notice period is. The exit is priced before the entry.

6. Is a per-country line item being charged? Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. requires “an economic operator established in the Union”, singular, established anywhere in the Union. One satisfies the whole internal market. A per-country line item has no provision in GPSR behind it, and the quote has to name the one it is charging for.

Before you shortlist, two last things. A UK representative is a separate purchase under separate law, and several vendors bundle it; if you do not sell into the UK, that bundle is a discount on something you do not need. And a turnaround claim is not a service level: “appointed in 24 hours” describes how fast the paperwork is signed, not how fast anyone answers a market surveillance authority.

A responsible person is one obligation out of about thirty that can reach a business selling into the Union. The rest - packaging, customs, VAT, data - are listed together in sell into the EU.

What the law leaves open

• How often “regularly” is in Art. 16(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex.. The text says regularly, and “where appropriate with regard to the possible risks related to a product”. It sets no interval. A fixed frequency quoted as a legal requirement is guidance or a provider’s own service level, not the Regulation. Meanwhile, agree an interval with your responsible person that fits the product’s risks, and keep the documented evidence of each check, which an authority can ask for.

• Whether clothing and other textile products need an EU company at all. The law can be read two ways, and the Commission’s guidelines of 21 November 2025 give no textile example. No court has ruled on it. This is a genuine edge case.

  1. Read literally, no. Textile labelling, Regulation (EU) No 1007/2011Regulation (EU) No 1007/2011, Textile Labelling RegulationThe whole regulationClick opens the law on the EU Publications Office., is on the list in Annex I to Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. (point 40), so a textile product is subject to specific requirements of Union harmonisation legislation, and Art. 2(1)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1, point (b)Click opens the article on EUR-Lex. switches off Articles 9 to 18 for it, Art. 16Regulation (EU) 2023/988, General Product Safety RegulationArticle 16Click opens the article on EUR-Lex. included. Regulation (EU) No 1007/2011Regulation (EU) No 1007/2011, Textile Labelling RegulationThe whole regulationClick opens the law on the EU Publications Office. is not on the Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex. list, so Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex. does not require one either.
  2. Read by the Commission’s furniture logic, yes. The guidelines say GPSR “applies fully” to furniture, which is “not subject to specific requirements imposed by other EU legislation” (C/2025/6233, section 2.2), although REACH, also on the Annex I list, reaches furniture. If a law on that list that sets no safety requirement for the product does not displace GPSR, then textile labelling does not displace Chapter III, Section 1 either, and Art. 16Regulation (EU) 2023/988, General Product Safety RegulationArticle 16Click opens the article on EUR-Lex. and Art. 9Regulation (EU) 2023/988, General Product Safety RegulationArticle 9Click opens the article on EUR-Lex. apply to a garment.

  Act as if the second reading applies: have an EU responsible person and meet the Art. 9Regulation (EU) 2023/988, General Product Safety RegulationArticle 9Click opens the article on EUR-Lex. duties. Amazon, eBay and Etsy ask for the field on an EU clothing listing as on any other, so the first reading saves you nothing in practice. Either way, GPSR’s general safety requirement covers a garment’s safety, because textile labelling sets no safety requirement (Art. 2(1)(a)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1, point (a)Click opens the article on EUR-Lex., Art. 5Regulation (EU) 2023/988, General Product Safety RegulationArticle 5Click opens the article on EUR-Lex.). Footwear sits the same way: its own law, Directive 94/11/EC on footwear labelling, is also on the Annex I list and not on the Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex. list.