# EU REP / EC REP Symbol: Do Consumer Products Need It Under GPSR?

> No. The GPSR does not require an EU REP or EC REP symbol on consumer products. See where the symbol applies and which name and address a GPSR label needs.

Published: 2026-10-31
Updated: 2026-10-31

Canonical page: [https://eugpsr.de/en/blog/eu-rep-symbol-gpsr-consumer-products](https://eugpsr.de/en/blog/eu-rep-symbol-gpsr-consumer-products)

No. The GPSR does not require an EC REP or EU REP symbol on consumer products. It requires written information: the name, registered trade name or trade mark, and the postal and electronic address of the manufacturer and of the operator established in the EU who is responsible for the product, shown on the product or, where the rules allow, on its packaging, the parcel or an accompanying document. The symbol belongs to the standard for medical device symbols, and its legal footing is in the medical device rules.

This guide separates what the law says, what the standard says and what is our own assessment. Where a statement is our judgement, we say so. For the full label rules, see our guides to [GPSR labelling requirements](https://eugpsr.de/en/blog/gpsr-labelling-requirements) and the [EU responsible person address on the label](https://eugpsr.de/en/blog/gpsr-responsible-person-address-on-label).

## What do the EC REP and EU REP symbols mean?

EC REP and EU REP mean the same thing: the manufacturer's authorised representative in the EU. EU REP is the current wording. These are the facts behind that:

1. An authorised representative is a person established in the EU who has a written mandate from a manufacturer outside the EU to act for it on specified tasks.
2. The symbol is defined in clause 5.1.2 of EN ISO 15223-1:2021, the standard on symbols for information supplied with medical devices. The 2021 edition shows EC REP for "Authorized representative in the European Community/European Union".
3. An amendment adopted by ISO in March 2025 (EN ISO 15223-1:2021/A1:2025) replaces the fixed "EC" with a placeholder, so the symbol reads "XX REP". For the EU, XX is replaced by EU, which gives EU REP.
4. "EC" stands for European Community, a term the Treaty of Lisbon replaced with European Union in 2009. The Medical Device Coordination Group (MDCG) describes the change as purely editorial: the representative's role and obligations stay the same.

The standard itself is sold by standards bodies. The points above rely on the MDCG guidance and the Commission decision listed in the sources at the end.

## Where is the EC REP / EU REP symbol legally relevant?

In the rules we reviewed, the symbol appears in the medical device regulations and their standard, and nowhere in the GPSR. For medical devices (Regulation (EU) 2017/745, MDR) and in vitro diagnostic devices (Regulation (EU) 2017/746, IVDR), four points matter:

1. If the manufacturer is outside the EU, the label must show the name of the authorised representative and the address of its registered place of business. That written information is the legal requirement.
2. Both regulations say information may take the form of internationally recognised symbols where appropriate, and that any symbol used must conform to the harmonised standards. This is how EN ISO 15223-1 becomes the reference for the EC REP / EU REP symbol.
3. The Commission published the reference to the amended standard in the Official Journal on 17 June 2026, for the MDR and for the IVDR.
4. The withdrawal of the old reference is deferred by five years, to June 2031. Until then, manufacturers may use EC REP, EU REP or both, also on different packaging levels, if the representative's details remain clear. After that date, only the standard with the amendment gives the presumption of conformity. Devices already on the EU market before that date may stay on sale.

If your product is a medical device or an in vitro diagnostic device, the medical device label rules apply to it, not the GPSR label rules in this guide. Check the product classification first.

## Do consumer products need the EU REP symbol under the GPSR?

No. The GPSR sets these label duties, and none of them mentions a symbol:

1. **Manufacturer:** name, registered trade name or trade mark, postal address and electronic address, plus the single contact point if it differs. The information goes on the product or, where that is not possible, on its packaging or in an accompanying document.
2. **Importer:** the same details for the importer, with the same placement rule. An additional label must not cover information that Union law requires on the manufacturer's label.
3. **EU responsible operator:** a product may not be placed on the EU market unless an operator established in the EU is responsible for it. Its name, registered trade name or trade mark, and contact details including the postal and electronic address must be on the product, the packaging, the parcel or an accompanying document. That operator can be an EU manufacturer, an importer, an authorised representative with a written mandate or, in defined cases, a fulfilment service provider.
4. **Online offers:** the listing must clearly and visibly show the manufacturer's details and, for a manufacturer outside the EU, the responsible person's name, postal address and electronic address. See [what online offers must show](https://eugpsr.de/en/blog/gpsr-online-sales-required-info).

Two further observations support the answer:

- The Commission's guidelines for businesses on the GPSR (published November 2025) do not mention EC REP, EU REP or any symbol or pictogram for operator identification. We searched the full text for those terms and found no hit.
- Regulation (EU) 2019/1020 has a parallel rule for products under harmonisation laws such as toys, machinery and radio equipment. It asks for the operator's name, trade name or trade mark, and contact details including the postal address. It does not mention a symbol either.

In practice you may still see EC REP printed on consumer goods. We read that as a habit carried over from medical device labelling, not as a GPSR requirement.

## EC REP symbol: medical devices compared with GPSR consumer products

| Question | Medical devices (MDR / IVDR) | Consumer products (GPSR) |
| --- | --- | --- |
| Legal basis | Regulations (EU) 2017/745 and 2017/746 | Regulation (EU) 2023/988, with Regulation (EU) 2019/1020 for the tasks of the responsible operator |
| Who is named | The authorised representative, if the manufacturer is outside the EU | The responsible operator in the EU: EU manufacturer, importer, authorised representative or fulfilment service provider |
| Is a symbol required? | No. Symbols are used where appropriate, and any symbol used must conform to the harmonised standard | No symbol is prescribed |
| Standard behind the symbol | EN ISO 15223-1 (EC REP, now also EU REP) | None for operator identification |
| What must be shown | Name of the representative and address of its registered place of business | Name, registered trade name or trade mark, postal address and electronic address |
| Where | On the device; if that is not practicable or appropriate, on the packaging | Responsible operator: product, packaging, parcel or accompanying document. Manufacturer and importer: product first, then packaging or document |
| Online listing | Not covered here | Manufacturer and responsible person details must be visible in the offer |

## What does a GPSR label need instead of the symbol?

A GPSR label needs written identification of each operator in the chain, and a product identifier. For a product from a manufacturer outside the EU, that means:

1. A product identifier such as a type, batch or serial number that consumers can easily see and read.
2. The manufacturer's name or trade mark, postal address and electronic address.
3. The importer's name or trade mark, postal address and electronic address, where an importer places the product on the EU market.
4. The name or trade mark, postal address and electronic address of the EU responsible operator. If an EU importer or EU manufacturer already fills that role, it may be the same entity as in point 3.
5. Instructions and safety information where the product needs them, in a language consumers can easily understand, as decided by the country where the product is sold. See the [warning and pictogram guide](https://eugpsr.de/en/blog/warning-pictograms-labelling-guide).

Two points about the addresses themselves. The Commission's guidelines explain that an electronic address can be an e-mail address or a dedicated section of a website that lets consumers contact the operator directly, and that a website alone is not enough if it does not allow direct communication. The Blue Guide adds that the address must indicate a single point at which the operator can be contacted. In our view, a fulfilment warehouse that is not the named entity's real contact address does not meet that test.

## What does an example GPSR label block look like?

The block below is an illustration with fictional companies. It is not a legal template. The wording of the headings is our choice, because the GPSR prescribes the content and not the format.

```text
Manufacturer
Example Maker Inc.
100 Sample Street, Exampleville 00000, United States
contact@example-maker.example

EU Responsible Person
Example EU Services GmbH
Musterstrasse 1, 12345 Musterstadt, Germany
gpsr@example-eu-services.example

Model EM-100 · Batch 2026-11-A
```

Some drafting notes for this block:

- Name the role in words. "EU Responsible Person" or "EU importer" tells a reader what the entity does. If the EU operator is an importer or an EU manufacturer, say so, because EU REP would describe the wrong role.
- Use the same names and addresses on the product, the packaging, the insert and the online listing. A marketplace reviewer or an authority will compare them.
- Add the product-specific warnings and instructions separately, in the language of the sales country.
- Where the block sits depends on the product's size and nature. The placement rules are in our [labelling requirements guide](https://eugpsr.de/en/blog/gpsr-labelling-requirements).

## Can I still print the EC REP or EU REP symbol on a consumer product?

We found no rule in the GPSR or in the Commission's guidelines that forbids a symbol next to the required details. Whether it is wise is a different question. This is our assessment, not a legal requirement:

1. **The symbol alone identifies nobody.** The GPSR asks for a name and a postal and electronic address. A symbol without them does not meet that duty.
2. **The symbol means authorised representative.** The GPSR operator can also be an importer, an EU manufacturer or a fulfilment service provider. Printing EU REP next to one of those would describe the role inaccurately. The difference between the roles is explained in [EU responsible person vs authorised representative](https://eugpsr.de/en/blog/eu-responsible-person-vs-authorised-representative).
3. **It can suggest a medical device.** Because the symbol comes from the medical device standard, a reader may link the product to that regime. For a candle, a toy or a kitchen item, that creates a question you do not need.
4. **It takes space and attention.** The Commission expects this information to be easy to see and read. A small symbol added to a crowded label works against that.
5. **EC is outdated wording.** If you print the symbol anyway, EU REP matches the current standard. Older packaging with EC REP and complete, correct details is not, in our view, a reason for a reprint on its own.

Our recommendation for a new label is to leave the symbol out and write the role, the name and both addresses in plain text. If you do print it, put it next to the full details and never in place of them.

## How can Grüner Baum GmbH help?

Grüner Baum GmbH acts as an EU responsible person for manufacturers outside the EU. Before we accept a product family, we check the technical documentation, the label and the online listing. Our address may be printed only after we have accepted the product family in writing. Annual plans start at €249 per year for one accepted low-risk product family, with unlimited SKUs within each accepted family. Read more about the [EU Responsible Person service](https://eugpsr.de/en/responsible-person) or [contact us](https://eugpsr.de/en/contact) with your product category and current label.

## Frequently asked questions about the EU REP symbol

### Do consumer products need the EU REP or EC REP symbol under the GPSR?

No. The GPSR does not prescribe an EU REP or EC REP symbol. It requires the name, registered trade name or trade mark, and the postal and electronic address of the manufacturer and of the EU-established responsible operator, written out and placed where the rules for each operator allow: on the product, its packaging, the parcel or an accompanying document. A symbol cannot replace those written details.

### What is the difference between EC REP and EU REP?

Nothing in meaning. Both mark the authorised representative in the EU. EC REP is the symbol in the 2021 edition of the medical device symbols standard, EN ISO 15223-1. Its 2025 amendment replaces EC, short for the outdated term European Community, with a placeholder, and EU REP is the EU version. The Medical Device Coordination Group calls the change purely editorial.

### Is the EC REP symbol still allowed?

For medical devices, yes, during a transition. The Commission published the amended standard on 17 June 2026 and deferred the withdrawal of the old reference until June 2031. In that period manufacturers may use EC REP, EU REP or both, as long as the representative's details stay clear. For consumer products under the GPSR, the regulation itself contains no symbol requirement.

### What does a GPSR label need instead of the symbol?

At minimum a product identifier such as a type, batch or serial number, the manufacturer's name or trade mark with postal and electronic address, the importer's details where there is an importer, and the name or trade mark with postal and electronic address of the EU responsible operator. Add instructions and safety information where the product needs them, in a language consumers in the sales country understand.

### Can I print the EU REP symbol on a consumer product anyway?

We found no rule that forbids it, but it adds nothing the GPSR asks for, and in our assessment it carries risks. It means authorised representative, which is not always the role of your EU operator. It can suggest a medical device. It also never replaces the written name and addresses. If you print it, put it next to the full details and keep those details easy to read.

### Where can I download the EU REP symbol?

The graphic is defined in the ISO 15223-1 standard, which standards bodies sell, and it is meant for medical device labelling. We do not supply the file. For a consumer product you do not need it: write the role and the full name and addresses in plain text.

### Is a website enough as the electronic address on the label?

Only if it lets consumers contact you directly. The Commission's guidelines say an electronic address can be an e-mail address or a dedicated section of your website, and that a website alone is not enough if it does not allow direct communication. A monitored e-mail address is the simplest choice.

## Official and technical sources

| Topic | Legal basis | Official text |
| --- | --- | --- |
| EC REP in clause 5.1.2, change to XX REP and EU REP, five-year coexistence period | MDCG 2021-5 Rev.1, Appendix (June 2026) | [MDCG appendix on the EU REP symbol](https://health.ec.europa.eu/document/download/e10f7694-67b4-4093-a969-6f7e43747c44_en?filename=md_mdcg_2021_5_appendix_en.pdf) |
| Publication of EN ISO 15223-1:2021/A1:2025 and deferred withdrawal (MDR) | Commission Implementing Decision (EU) 2026/1231, recitals 4 and 12, Art. 2 | [Decision (EU) 2026/1231 (EUR-Lex)](https://eur-lex.europa.eu/eli/dec_impl/2026/1231/oj) |
| Name and address of the authorised representative on the device label | MDR, Annex I, 23.2(d) | [Regulation (EU) 2017/745 (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2017/745/oj) |
| Symbols must conform to harmonised standards | MDR, Annex I, 23.1(h) | [Regulation (EU) 2017/745 (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2017/745/oj) |
| Name and address of the authorised representative on the IVD label | IVDR, Annex I, 20.2(d) | [Regulation (EU) 2017/746 (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2017/746/oj) |
| Manufacturer name, trade name or trade mark, postal and electronic address | GPSR Art. 9(6) | [GPSR text (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2023/988/oj) |
| Importer details; additional label must not obscure manufacturer information | GPSR Art. 11(3) | [GPSR text (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2023/988/oj) |
| EU responsible operator required; its name and contact details on product, packaging, parcel or document | GPSR Art. 16(1) and 16(3) | [GPSR text (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2023/988/oj) |
| Information required in online offers | GPSR Art. 19 | [GPSR text (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2023/988/oj) |
| Types of responsible operator; name and contact details with postal address | Regulation (EU) 2019/1020, Art. 4(2) and 4(4) | [Regulation (EU) 2019/1020 (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2019/1020/oj) |
| Meaning of electronic address; information must be easy to see and read | Commission Notice C/2025/6233 | [Commission guidelines (EUR-Lex)](https://eur-lex.europa.eu/eli/C/2025/6233/oj) |
| Address must indicate a single point of contact | Blue Guide 2022, section 4.2.2 | [Blue Guide (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.C_.2022.247.01.0001.01.ENG) |

This article is general information, not legal advice.