GPSR responsible person: who it can be and what they do
Checked against the sources on 6 October 2026
A consumer product can only be placed on the EU market if an economic operator established in the EU is responsible for it (Article 16(1)). For manufacturers outside the EU this is the most practical question of the GPSR.
Who can be the responsible person
Article 16 applies the rule in Article 4 of the market surveillance regulation (EU) 2019/1020. The responsible person is one of these, in this order:
- the manufacturer, if it is established in the EU;
- the importer, if the manufacturer is not established in the EU;
- an authorised representative with a written mandate from the manufacturer;
- a fulfilment service provider established in the EU, where none of the above is established in the EU.
Importers and authorised representatives are established in the EU by definition (Article 3(9) and (10)). A warehouse or agent outside the EU cannot take the role.
What the responsible person does
- keeps the technical documentation available for the authorities and provides information on request;
- informs the authorities when it believes a product presents a risk, and cooperates with them;
- where appropriate to the risks, regularly checks that the product matches its technical documentation and carries the product identification, contact details and instructions, and keeps evidence of these checks (Article 16(2)).
Where their details go
Name, registered trade name or trade mark, and contact details including postal and email address, on the product, its packaging, the parcel or an accompanying document (Article 16(3)). Online offers must also show them when the manufacturer is outside the EU (Article 19(b)).
Products with their own EU law
Article 16 of the GPSR does not apply to products covered by EU harmonisation legislation (Article 2(1)). Many of those products need an EU economic operator anyway, under Article 4 of Regulation (EU) 2019/1020 itself; check the law that covers your product.
Selling from outside the EU? The GPSR check tells you whether you need one, based on your role and sales channel.