EU Responsible Person Under GPSR: Who Qualifies, How to Appoint and What They Must Do

Amazon has stated it will provide responsible person services for sellers using FBA for products sold in the EU. However, this service is subject to conditions: (1) you must use FBA for the relevant EU marketplace; (2) the service scope may be limited to certain product categories; (3) Amazon charges a fee (check Seller Central for current pricing). If you sell through your own DTC store and ship directly from outside the EU (not using FBA), you cannot rely on Amazon's responsible person service — you must appoint your own. Third-party responsible person services are available from companies like EU Rep, Compliance Gate, and various EU-based consultancies. Always get written confirmation of the appointment specifying the products covered.

The responsible person must: (1) maintain and provide, upon request, the technical documentation demonstrating product safety (or know where to access it); (2) provide market surveillance authorities with all information and documentation necessary to demonstrate product safety, in a language easily understood by the authority; (3) cooperate with authorities on actions to eliminate risks posed by products (recalls, withdrawals); (4) inform the relevant authority if they have reason to believe a product is unsafe, and take corrective action. The responsible person does NOT need to hold the goods physically or conduct testing — but they must be able to access safety documentation and respond to authority requests within defined timelines (typically 5-10 working days).

Products without a visible EU responsible person face multiple enforcement risks: (1) customs authorities can block the shipment at the EU border — this is the most immediate risk, as customs officers are instructed to check for GPSR compliance markers; (2) online marketplaces (Amazon, bol.com, Zalando) have begun proactively removing listings that lack responsible person information; (3) market surveillance authorities can order product recalls or withdrawals; (4) fines vary by member state — Germany up to €500,000, France up to €300,000. The enforcement has been active since 13 December 2024. There is no grace period. If you are already selling in the EU without a responsible person, you should appoint one immediately and update your product labelling.

Market rates for third-party responsible person services in the EU: (1) basic service (address listing + document storage): €200-500 per year per product category; (2) full service (includes authority liaison, document translation, recall coordination): €500-1,500 per year; (3) enterprise/high-volume: negotiated rates, typically €1,000-3,000+ per year for multiple categories. Some providers charge per-SKU rather than per category. When choosing a provider, verify: (a) they have a physical address in an EU member state; (b) they can respond to authority requests in the local language; (c) they offer 24-48 hour response times for urgent safety notifications; (d) they provide written documentation of the appointment that you can show to customs or marketplaces.

No, they serve different legal functions and are governed by different regulations. The GPSR responsible person handles general product safety (safety information, authority liaison, recall coordination). A CE authorised representative is specific to products covered by CE marking directives (e.g., Machinery Regulation, PPE Regulation, Radio Equipment Directive) and handles EU declaration of conformity, technical file maintenance, and CE marking compliance. A product may need both: a GPSR responsible person for general safety and a CE authorised representative for specific directive compliance. Some service providers offer combined packages covering both roles at a reduced rate. Check your product's applicable directives to determine if a CE authorised representative is also required.