GPSR on Amazon: what goes in the Responsible Person field

The Responsible Person field sits in Seller Central. What goes in it is an EU contact for the product plus the manufacturer’s contact details.

What Amazon asks for

From the GPSR implementation announcement in Amazon’s Seller Forums, posted by an Amazon staff account. Amazon’s words:

“We’re sharing some crucial updates regarding the upcoming implementation of the General Product Safety Regulation (GPSR) in the European Union (EU), including Northern Ireland, under the Northern Ireland Protocol.”

“For listings on Amazon UK-based store, you don’t need to submit any information to Amazon. You must, however, submit the required information for listings on Amazon EU-based stores.”

“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.”

“Manufacturer Information: Label your products with the manufacturer’s contact details and, if applicable, the importer’s information. Ensure the visibility of this information on both physical products and online listings.”

“Submitting Information to Amazon: Use the Add compliance information widget in the Manage your compliance dashboard to provide necessary details.”

“Displaying Information on Product Pages: Responsible Person and manufacturer information, along with relevant images and safety documents, will be displayed on product detail pages within 24 hours of confirmation.”

Your own address does not take you out of it. An offer targeted at consumers in the Union is deemed to make the product available on the market (Art. 4Regulation (EU) 2023/988, General Product Safety RegulationArticle 4Click opens the article on EUR-Lex.). Whether GPSR reaches your particular product is settled by the page on whether GPSR applies to you.

A distance offer must show, clearly and visibly, the manufacturer’s name and postal and electronic address, the responsible person where the manufacturer is not EU-based, an identification of the product including a picture of it, and any warning or safety information in a language consumers can easily understand (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.). That is the duty Amazon’s widget collects against.

The field itself exists because the marketplace has to build it. A provider of 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 must design its interface so traders can supply exactly that information for each product offered (Art. 22(9)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9Click opens the article on EUR-Lex.).

Labelling the product is a second duty, separate from filling the dashboard. The responsible operator’s contact details 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.); what the label has to carry is GPSR labelling requirements.

Manage Your Compliance is where the field is

Seller Central, then the Manage your compliance dashboard, then the Add compliance information widget. That is the route Amazon names in its public announcement, and the dashboard behind it opens only to a seller account.

Amazon’s own GPSR help-hub articles in Seller Central also open only to signed-in sellers. Without a session the help-hub address returns an empty page shell and no article text. The Amazon words quoted here come from its public Seller Forums and its public blog, which open without an account.

Submission required and submission under review

Sellers on Amazon’s forum report two statuses on their GPSR submissions: “submission under review”, which after a time can fall back to “submission required” (Amazon Seller Forums). Amazon’s GPSR help article shows no text without a seller login. Its public page on submitting compliance information says only that a submission goes “for our review” (Amazon); it names no status and no review time, so this page cannot say what each status triggers or how long a review takes. Amazon’s announcement adds that the details appear on the product page “within 24 hours of confirmation”, without saying who confirms. If a status does not move, the route is what keeps a listing blocked.

Outside the EU, Amazon still says yes

The most asked question in the public threads is “Do I need one if I am not in the EU?”, and Amazon answered it directly. In a Seller Forums thread on an EU-based Responsible Person for US-based sellers, a seller put it this way:

“As a US-based reseller, all our suppliers are also based in the United States, and we currently do not have any contacts in Europe. In light of this, we would like to understand if we are still required to designate an EU-based Responsible Person.”

An Amazon community manager replied:

“Short answer, yes, all sellers (including non-EU based) are required to appoint an EU-based Responsible Person for the products.”

The Regulation’s own rule is narrower: it does not require you to appoint anybody. It says a product may not be placed on the market unless 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 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) 2019/1020 for that product (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.). 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, an EU subsidiary that manufactures, an EU business already holding a written mandate: any of those already in your chain meets the condition, and no new contract is needed.

For a toy, an electrical or radio product, machinery or protective equipment, GPSR Art. 16Regulation (EU) 2023/988, General Product Safety RegulationArticle 16Click opens the article on EUR-Lex. does not apply (Art. 2(1)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1, point (b)Click opens the article on EUR-Lex.). Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. asks for the same EU company instead (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex.), and its details go in Amazon’s field the same way (Art. 19(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (b)Click opens the article on EUR-Lex., Art. 22(9)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9, point (b)Click opens the article on EUR-Lex.). Which rule covers your product is on the EU Responsible Person.

Who is eligible, and what the market charges, is the EU Responsible Person. If the role Amazon names is not the one your customer or your freight forwarder is asking about, the three similar names are separated in EU authorised representative.

If you leave it empty, the listing can be removed or deactivated

Already filled it in and still blocked? That is a different problem: what keeps a listing down after you send your details.

Amazon states the consequence in one line of the same announcement:

“Proving Compliance to Amazon: Ensure compliance with GPSR requirements for EU-based stores. Non-compliant listings risk removal and ineligibility for flash sales.”

Sellers call a listing in that state removed, deactivated, blocked or inactive. Amazon itself says it will “deactivate your non-compliant listings” when you cannot prove EPR compliance in Germany (Amazon), and the EPR guide gives its stages. Sellers in the public reply thread describe a GPSR block arriving as invisibility rather than as a notice. One reply reads in full:

“is this the reason my listings have all become invisible to buyers?”

Amazon’s public blog page on the Manage Your Compliance dashboard sets out the general mechanics of missing compliance documentation. It is bylined 3 August 2022, so it pre-dates GPSR and is not about GPSR:

“If a product lacks the right compliance documentation, your listings could be removed, which might affect your Account Health. If you ship internationally, non-compliant items might get stopped in customs. And if you have inventory at Amazon fulfillment centers, non-compliant products might be disposed of.”

Amazon publishes the way out in the announcement too: “Removing Products from Sale: If not continuing sales in EU stores, remove affected products from inventory via Manage Inventory dashboard or FBA.”

None of that is the law’s own consequence. GPSR sets no figure itself: each EU country lays down the rules on penalties for infringements and takes the measures needed to implement them, 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 GPSR fines.

Separately, a marketplace must suspend, after a prior warning, its services to traders that frequently offer non-compliant products (Art. 22(11)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 11Click opens the article on EUR-Lex.).

Who can fill it for you

The route that costs nothing comes first. Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. is a condition on the product, not a purchase. An EU subsidiary that manufactures, an EU importer of record, 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 all satisfy it, and their details are what goes into Amazon’s field. Filling the dashboard costs nothing. Money buys one thing only: an EU-based operator willing to take those tasks where you have nobody. The eligibility test is on the EU Responsible Person, and Amazon does not decide it.

One appointment covers every channel. The obligation in Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. attaches to the product, not to the marketplace, so the same operator’s details go into Amazon’s field, Etsy’s and eBay’s alike.

The Digital Services Act trader checks are separate from GPSR

If Amazon asks for your identity document, your bank account and a statement that you comply with EU law, that is not the Responsible Person field. Those match the trader checks the Digital Services Act, Regulation (EU) 2022/2065Regulation (EU) 2022/2065, Digital Services ActThe whole regulationClick opens the law on the EU Publications Office., requires of a marketplace. A marketplace that lets consumers buy from traders, unless it is a micro or small enterprise, must hold your name, address, telephone number and email address, a copy of your identification document, your payment account details, your trade register number where you have one, and your self-certification before it lets you offer products to consumers in the EU (Art. 30(1)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 1Click opens the article on EUR-Lex.). It must make best efforts to check them, and must suspend its service to you if you do not correct an item (Art. 30(2)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 2Click opens the article on EUR-Lex., Art. 30(3)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 3Click opens the article on EUR-Lex.). Its listing form must also let you give the product safety information, which is the field this page is about (Art. 31(1)Regulation (EU) 2022/2065, Digital Services ActArticle 31, paragraph 1Click opens the article on EUR-Lex.). Amazon’s public pages read for the Digital Services Act guide do not name the Act, so this page cannot say which Amazon screen belongs to which law. The items, the checks and the complaint route are in Digital Services Act trader checks.

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