Amazon GPSR Compliance for Cross-Border Sellers: EU Responsible Person and Product Safety

The EU Responsible Person under GPSR must be established within the EU and can be: (1) the manufacturer if established in the EU; (2) the importer (any EU-based entity importing the product); (3) an authorised representative mandated by the manufacturer. For non-EU sellers, the most common option is appointing a specialised compliance service provider as authorised representative. The Responsible Person's name, registered postal address and electronic contact address (email) must appear on the product, its packaging, or a document accompanying the product. Amazon verifies this information during listing.

Amazon requires sellers to provide: (1) Responsible Person details — name, postal address, email and phone number; (2) product safety documentation — risk assessment, test reports, conformity declarations (CE marking documentation where applicable); (3) product images — showing safety markings, warnings and the Responsible Person's details on packaging; (4) Safety Information File — accessible via a URL or QR code on the listing. For products requiring CE marking, you also need the EU Declaration of Conformity and technical file. Amazon may request these documents at any time, not just at listing creation.

GPSR covers all consumer products placed on the EU market — any product intended for consumers or likely to be used by consumers, even if not designed for them. This includes: clothing and textiles, toys, cosmetics, electronics, furniture, kitchenware, sports equipment, jewellery, stationery, and general household items. Products already covered by specific EU safety legislation (e.g., medical devices under MDR, food under food safety law) are excluded from GPSR's scope but remain subject to their own sector-specific regulations. Second-hand goods and antiques are excluded.

Under GPSR, national market surveillance authorities can: (1) order product recalls at the seller's expense; (2) impose fines — maximum penalties vary by country (Germany: up to €10 million or 4% of annual turnover; France: up to €300,000 for legal entities; Italy: €10,000-€500,000); (3) block products from the market via the Safety Gate (RAPEX) rapid alert system; (4) require corrective actions (warnings, modifications) within specified deadlines. Amazon separately blocks non-compliant listings. Repeat violations can result in permanent marketplace bans and criminal liability in some member states.

For non-EU sellers, the most practical option is appointing a specialised compliance service provider as your EU Responsible Person. Providers charge €200-€3,000/year depending on product categories and the number of SKUs. When selecting a provider, verify: (1) they have a physical address in an EU member state; (2) they are willing to accept legal responsibility for product safety documentation; (3) they can provide their details for your product labels and packaging; (4) they have experience with your product category. Popular providers include Obelis (Belgium), EC-REP (Germany), and various law firms with EU product safety practices. The manufacturer must issue a formal mandate (written authorisation) to the Responsible Person, and their name, postal address and email must appear on the product or its packaging.