# Who Must Be Your EU Responsible Person Under the GPSR?

Source: https://activatedigital.ai/knowledge/regulation/gpsr-responsible-person
Last verified: 12 September 2026
Summary: A product can be placed on the EU market only if an operator established in the Union carries Article 16. Who can be one, what they do, what goes on the pack.

## Direct answer

**It is not a role you appoint. It is a condition the product has to satisfy before it can be placed on the Union market, and four kinds of business can satisfy it.**

Article 16 of Regulation (EU) 2023/988, the General Product Safety Regulation, is headed "Responsible person for products placed on the Union market". It says a product may be placed on the Union market only if there is an economic operator established in the Union responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020.

So the question "who must be our responsible person" has a shape most businesses do not expect. Nobody is required to be one. The product is required to have one, and if the chain does not contain a business that qualifies, the product cannot be placed on the market at all.

## Who can satisfy it

Article 4(2) of Regulation (EU) 2019/1020 names four, and they are ordered. The first one that exists in your chain is the answer:

|  | Who | When this is the answer |
|---|---|---|
| a | A manufacturer established in the Union | You make the product in the Union. The question is already answered. |
| b | An importer | The manufacturer is not established in the Union and somebody in the Union imports the product. |
| c | An authorised representative | Someone holds a written mandate from the manufacturer to act as one. |
| d | A fulfilment service provider established in the Union | Nobody above exists, and a fulfilment service provider handles the product. |

Read that list against your own chain rather than against your org chart. A non-EU brand selling direct to EU consumers with no EU importer has two realistic answers, (c) and (d), and only one of them is a decision it makes itself.

## What the responsible person actually has to do

Four tasks, from Article 4(3) of Regulation (EU) 2019/1020:

- Verify that the EU declaration of conformity or performance and the technical documentation have been drawn up, and keep them available to market surveillance authorities for the required period.
- Provide authorities, on a reasoned request, with the information and documentation that demonstrates conformity, in a language they can understand.
- Inform authorities where there is reason to believe the product presents a risk.
- Cooperate with authorities, and ensure immediate corrective action is taken to remedy non-compliance or, failing that, to mitigate the risk.
Article 16(2) of the GPSR adds one more that is specific to it: the responsible person has to carry out regular checks that the product conforms to the technical documentation and the manufacturer's own requirements, and keep documented evidence of those checks available to authorities on request.

That last one is the difference between a mailbox and a responsible person. A business that takes the role on and never looks at the product is not doing the thing the Regulation describes.

## What it is not

It is not an authorised representative in the conformity-assessment sense unless that is the route you have chosen. (c) above is one of four ways to satisfy the condition, not the definition of it.

It is not a distributor. A distributor has its own obligations and they are a different set.

It is not the same as the registrations a company needs before a marketplace will let it list. Those are covered by [the registrations that gate a listing](https://activatedigital.ai/knowledge/regulation/registrations-that-gate-a-listing), and they are about your company rather than about any one product.

It does not make the product compliant. Every task above is verification, cooperation and evidence. None of them is a substitute for the product being safe.

## What has to appear on the product

Article 16(3) of the GPSR requires the responsible person's name, registered trade name or registered trade mark, and contact details, including postal and electronic address, to be indicated on the product, on its packaging, on the parcel or in an accompanying document.

Article 4(4) of Regulation (EU) 2019/1020 requires the same thing for the products it covers.

So this is not a back-office arrangement. It gets printed, and it gets printed on something that reaches the consumer.

## Why the GPSR needed its own Article 16

Article 4 of Regulation (EU) 2019/1020 does not apply to everything. Article 4(5) limits it to products subject to a list of named Union harmonisation legislation, which is how sector-regulated products get the responsible-person condition.

Consumer products that sit outside that list had no equivalent. Article 16 of the GPSR applies the same architecture to products within the GPSR's scope, by requiring the Article 4(3) tasks rather than by writing a second set of them.

That is worth knowing for two reasons. It tells you where to look when a product is covered by both, and it tells you why the tasks are described in a regulation that is not the one you were reading.

## What this means for an online offer

Where the manufacturer is not established in the Union, Article 19 of the GPSR requires the offer itself to indicate the responsible person's details. Not the account, not the terms page, the offer.

That is the point at which this question stops being a compliance file and starts being a listing field, and it is the subject of [what an EU online offer must show](https://activatedigital.ai/knowledge/regulation/gpsr-online-listing-product-information).

## What would change this answer

Recheck if:

- Article 4(5) of Regulation (EU) 2019/1020 is amended to change which legislation it
covers;

- Article 16 of the GPSR is amended;
- guidance changes the interpretation of what a fulfilment service provider is for the
purposes of Article 4(2)(d).

**Last verified 12 September 2026.**

## Keep exploring

The questions this page usually raises next.

- [CompareNext questionWhat Product Information Must an EU Online Listing Show Under the GPSR?The manufacturer, responsible person, product identifiers and safety information an online offer to EU consumers must indicate.→](https://activatedigital.ai/knowledge/regulation/gpsr-online-listing-product-information)
- [CompareNext questionEPR Registration and Responsible PersonAlmost everything blocking a listing today is a fact about the business, not the garment.→](https://activatedigital.ai/knowledge/regulation/registrations-that-gate-a-listing)
- [What to do nextNext questionDigital Product Passports for Importers: What Data and Evidence You Need From the ManufacturerIf you import a product into the EU, the DPP job starts before the border.→](https://activatedigital.ai/knowledge/guides/dpp-importers-upstream-evidence)

## Sources and legal basis

- [Regulation (EU) 2023/988, General Product Safety Regulation, consolidated text](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)