EU Responsible Person for US Sellers: Do You Need One? (2026)
As of 5 October 2026, a US-based seller usually needs an EU Responsible Person for consumer products sold into the EU. Under the GPSR, such a product may not be placed on the EU market unless a business established in the EU is responsible for a set of product-safety tasks, and a US company is not established in the EU. That role must sit with someone else: an EU importer, an authorised representative with a written mandate or, as a fallback, an EU fulfilment service provider.
Which of these fits you depends on how your goods reach EU consumers, and that is what this guide works through. The exact legal references are collected in the sources table at the end.
The GPSR is the EU's General Product Safety Regulation, Regulation (EU) 2023/988. It has applied since 13 December 2024. If you first want the role itself explained, read our EU Responsible Person guide. This article is the decision guide by sales route. For everything else you need to sell in Europe, including VAT, customs and producer responsibility, see what you need to sell in Europe from the US or UK.
Does the GPSR responsible-person rule cover my product?
Most everyday consumer products are covered, but check two points first.
- Is it a consumer product in GPSR scope? The GPSR covers products meant for consumers, and products that consumers are likely to use in reasonably foreseeable conditions. Some categories are excluded altogether, for example food, medicinal products and antiques.
- Does the product have its own EU product law? Some products are covered by product-specific EU "harmonisation" legislation. For them, the GPSR's general duties for manufacturers, importers, distributors and the responsible person do not apply. A similar responsible-person rule may then come from the EU market surveillance regulation, but only for the product laws that regulation lists. The GPSR's rules for online listings still apply to these products.
If your product is CE-marked or otherwise covered by its own EU legislation, check that legislation before relying on this guide. The answer can differ.
Which sales route are you using, and who can be your EU Responsible Person?
The answer follows the real flow of goods, not your company name or what a partner calls itself. Two rules do most of the work:
- An online offer counts as making the product available in the EU as soon as the offer is aimed at consumers in the EU.
- "Placing on the market" means the first time a product is made available on the EU market.
Read together, our understanding is that the Responsible Person question has to be settled before your listing targets EU consumers, not when the parcel arrives. With that in mind:
| Your sales route | Is there an EU-established importer? | Who can be your EU Responsible Person? | What you must do |
|---|---|---|---|
| Marketplace with EU stock (for example Amazon FBA or another EU warehouse) | It depends. An importer is a business established in the EU that places a product from outside the EU on the EU market. If your US company ships its own stock into the EU warehouse, there may be no EU importer. If an EU-established company genuinely imports the stock, there is one. | The EU importer, if there is one. Otherwise, an authorised representative with a written mandate from the manufacturer. Only if neither exists, a fulfilment service provider established in the EU, and only for the products it handles. | Establish who imports the stock before you ship. Do not assume a warehouse operator takes on the fulfilment fallback; confirm in writing which role, if any, it accepts. Put that operator on the label and in the listing. |
| Cross-border shipping from US stock (own web shop, marketplace orders you fulfil yourself, Etsy, eBay) | Usually no. Our reading is that the EU consumer is not an importer, because placing on the market happens in the course of a business activity. Postal and parcel delivery services also do not count as fulfilment service providers. | In practice, an authorised representative with a written mandate. | Appoint the Responsible Person before the offer targets EU consumers. Show its details on the parcel or product and in every EU-targeted listing. |
| Selling to an EU importer or distributor (B2B) | Yes, if your EU customer is established in the EU and is the one that places the goods on the EU market. A distributor that buys from another EU company is not the importer. | The EU importer. | Agree in writing that the importer takes on the Responsible Person tasks. The importer also has its own duties, including adding its own contact details and keeping the technical documentation available for the authorities. |
| Mixed: B2B to an EU importer and direct sales to EU consumers | Yes for the imported units; usually no for the direct sales. | Possibly two different operators for the same SKU. | Map each route separately. The name on the label and in the listing must match the operator for the units actually sold through that route. |
The importer route in detail is covered in our guide to the EU importer as your Responsible Person. If you sell on Amazon specifically, see our Amazon GPSR page. We do not describe what any marketplace requires in this article, because platform rules are set by the platform and can change.
Who can legally be the EU Responsible Person?
The EU market surveillance regulation lists four possible operators, and the GPSR applies that list to the products it covers. In its rules for online listings, the GPSR calls whichever operator fills the role the "responsible person".
| Route | What the law says | What it means for a US seller |
|---|---|---|
| EU manufacturer | A manufacturer established in the EU | Not available if you are the manufacturer and you are based in the US. |
| Importer | An importer, where the manufacturer is not established in the EU | Available only when an EU-established company actually imports the goods. |
| Authorised representative | An authorised representative with a written mandate from the manufacturer to carry out the Responsible Person tasks | The usual route for direct sales. The mandate comes from the manufacturer. |
| Fulfilment service provider | A fulfilment service provider established in the EU, for the products it handles, where no manufacturer, importer or authorised representative is established in the EU | A fallback only, and only for the products that provider handles. |
Two points matter for US sellers:
Are you the manufacturer? Under the GPSR, the manufacturer is whoever makes a product, or has it designed or made, and markets it under their own name or trademark. Anyone who places a product on the market under their own name or trademark is treated as the manufacturer. If you sell your own brand, you are likely the manufacturer for GPSR purposes. If you resell another company's brand, the written mandate has to come from that manufacturer, so you will need its cooperation.
The fulfilment fallback has conditions. A fulfilment service provider offers at least two of these services: warehousing, packaging, addressing and dispatching, without owning the products. It can only step in where no manufacturer, importer or authorised representative is established in the EU. Whether a particular warehouse meets that definition, and whether it accepts the tasks, are facts to confirm with it directly.
For the difference between "Responsible Person" and "authorised representative", see Responsible Person vs authorised representative. Short definitions are in our GPSR glossary.
What does the Responsible Person actually do?
The four core tasks come from the EU market surveillance regulation, and the GPSR applies them to the products it covers.
| Task | What it means in practice |
|---|---|
| Documents | Check that the required documents have been drawn up, such as the EU declaration of conformity or declaration of performance and the technical documentation, where the product's rules require them. Make sure the technical documentation can be given to the authorities on request. |
| Authority requests | When an authority sends a reasoned request, give it all the information and documents it needs to see that the product complies, in a language the authority can easily understand. |
| Risk information | Tell the authorities when there is reason to believe the product presents a risk. |
| Corrective action | Work with the authorities so that problems are fixed or the risk is reduced, and, after a reasoned request, make sure the immediate, necessary corrective action is taken. |
The GPSR adds two more duties:
- Regular checks. Where the possible risks make it appropriate, the Responsible Person must regularly check that the product matches its technical documentation and carries the required identifier, manufacturer details, instructions and safety information. It must show the authorities documented evidence of those checks on request.
- Accidents. Where the manufacturer is not established in the EU, a Responsible Person who learns of an accident must make sure it is notified.
None of this moves the manufacturer's duties. The Responsible Person's tasks come on top of the other businesses' duties, so the risk analysis and the technical documentation remain the manufacturer's job.
What must appear on the product and in the online listing?
There are two sets of information: one on the physical product, and one in the offer the consumer sees before buying.
On the product, packaging, parcel or accompanying document
| Information | Where |
|---|---|
| Responsible Person: name, registered trade name or registered trade mark, contact details including postal and electronic address | On the product or its packaging, the parcel or an accompanying document |
| Manufacturer: name, registered trade name or registered trade mark, postal and electronic address | On the product, or where that is not possible, its packaging or an accompanying document |
| Type, batch or serial number or other identifier | On the product, or if its size or nature does not allow it, the packaging or an accompanying document |
| Instructions and safety information | In a language easily understood by consumers, as decided by the EU country where the product is sold (unless the product can be used safely without them) |
A QR code or other digital format can be used in addition, not instead: the GPSR only allows this information to be given digitally on top of the printed details.
In the online offer (distance sales)
Every online offer must show at least the following, clearly and visibly:
- the manufacturer's name, registered trade name or registered trade mark, and postal and electronic address;
- where the manufacturer is not established in the EU, the name, postal and electronic address of the Responsible Person;
- information identifying the product, including a picture, its type and any other product identifier;
- any warning or safety information required on the product or packaging, in a language consumers can easily understand.
Online marketplaces have a matching duty: they must design their online interface so traders can provide this information on each listing. Our guide to GPSR online-sales information goes through each point with examples.
What mistakes do US sellers make most often?
| Mistake | Why it is a problem |
|---|---|
| Buying an EU address with no tasks behind it. | The Responsible Person must actually carry the safety tasks, not only provide an address. |
| No written mandate, or a mandate from the wrong company. | An authorised representative needs a written mandate from the manufacturer, and must give the authorities a copy of it on request. |
| The label names a company that is not the Responsible Person for that route. | The details shown must be those of the Responsible Person for that product. An EU business customer that never imports your direct-to-consumer units is not their importer. |
| The listing is missing the Responsible Person or manufacturer details. | The offer must show both when the manufacturer is outside the EU. |
| Relying on the fulfilment fallback when another operator exists. | The fallback only applies where no manufacturer, importer or authorised representative is established in the EU. |
| Using a QR code instead of the printed details. | Digital information is allowed only in addition. |
| Treating the Responsible Person as a product certificate. | The manufacturer's risk analysis and technical documentation are still required. |
| Instructions only in English. | The language is decided by the EU country where the product is made available. |
What happens if it goes wrong? The GPSR does not set a fine amount itself. Each EU country sets its own penalties, and they must be "effective, proportionate and dissuasive". Separately, authorities can order marketplaces to remove offers of dangerous products. Marketplaces must also suspend traders that frequently offer non-compliant products, after a prior warning.
How can Grüner Baum help?
Grüner Baum GmbH (HRB 52165, Vorstädter Str. 32, 55276 Oppenheim, Germany) acts as EU Responsible Person for non-EU manufacturers where a written authorised-representative mandate is the correct GPSR route. That makes it most relevant to the direct-shipping route in the table above, and to EU-stock routes where no EU importer exists.
- Review first. We accept a mandate only after reviewing the product, the manufacturer, the supply chain and the available safety records, including labels and online-offer information.
- Price. Annual plans start at €249 per year for one accepted low-risk product family, with unlimited SKUs within each accepted family. Products subject to specific EU legislation and higher-risk products are quoted after review.
- Included in the Starter plan. Appointment as your EU Responsible Person under a written mandate, an initial risk analysis, weekly Safety Gate monitoring and one market-surveillance authority correspondence per contract year.
- Limits. The service is not a product certificate. It does not guarantee marketplace, customs or authority approval, and it does not replace the manufacturer's own responsibility.
See our EU Responsible Person service and all annual plans.
Frequently asked questions
What do I need to sell in Europe as a US seller?
For product safety, you need a safe product, a business established in the EU that is responsible for it, the required details on the label and in every online listing, and compliance with any product-specific EU law. VAT, customs, producer responsibility and consumer rules are separate topics; our guide on what you need to sell in Europe lists them with official sources.
Do I need an EU Responsible Person if I am a US seller?
If the GPSR responsible-person rule covers your consumer product, it may not be placed on the EU market unless a business established in the EU is responsible for a set of product-safety tasks. A US company is not established in the EU, so someone else has to fill that role: an EU importer, an authorised representative with a written mandate or, only as a fallback, an EU fulfilment service provider.
Does the law say I need one even if I only ship from the US to EU customers?
Selling online counts as soon as your offer is aimed at consumers in the EU. On that route there is usually no EU importer, because an importer must be established in the EU, and postal and parcel services do not count as fulfilment service providers. In practice that leaves an authorised representative with a written mandate, but check your own route.
Can Amazon, Etsy or eBay be my EU Responsible Person?
This guide does not describe any platform's policy. Legally, the EU market surveillance regulation lists four possible operators, and “online marketplace provider” is not one of them. Marketplaces have their own GPSR duties, including letting you show the Responsible Person's details on each listing. Ask any company in writing which of the four roles it accepts for your product.
What does the Responsible Person actually have to do?
Four core tasks come from the EU market surveillance regulation: check that the required documents have been drawn up, give the authorities information when they send a reasoned request, tell them when there is reason to believe the product presents a risk, and cooperate on corrective action. The GPSR adds regular checks, where the product's risks make them appropriate, that the product matches its technical documentation and its label information.
Where must the Responsible Person's details appear?
On the product or its packaging, the parcel or an accompanying document, and in the online offer when the manufacturer is not established in the EU. The name and the postal and electronic address are required in both places.
Does appointing a Responsible Person make my product compliant?
No. The Responsible Person's tasks come on top of the duties of the other businesses in the supply chain and do not replace them. The manufacturer's own duties, such as the internal risk analysis and the technical documentation, stay with the manufacturer.
Official sources
This table gives the exact legal basis for each rule this guide relies on. The GPSR points were checked against the consolidated text applicable from 29 May 2026, and the market surveillance points against the consolidated text of 12 August 2026.
| Topic | Legal basis | Official text |
|---|---|---|
| The GPSR has applied since 13 December 2024 | GPSR Art. 52 | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
| Which products are covered: consumer products, with some categories such as food, medicinal products and antiques excluded | GPSR Art. 3(1), Art. 2(2) | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
| Products with their own EU product law: the GPSR's general business duties, including the responsible-person rule, do not apply, but the online-listing rules do; the market surveillance regulation's own rule covers only the product laws it lists | GPSR Art. 2(1); (EU) 2019/1020 Art. 4(1), Art. 4(5) | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026; Regulation (EU) 2019/1020, consolidated text of 12 August 2026 |
| A business established in the EU must be responsible before the product is placed on the market; the four possible operators, with the fulfilment service provider only as a fallback; the four core tasks | GPSR Art. 16(1); (EU) 2019/1020 Art. 4(2), Art. 4(3) | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026; Regulation (EU) 2019/1020, consolidated text of 12 August 2026 |
| An online offer aimed at EU consumers counts as making the product available; placing on the market is the first making available, in the course of a business activity | GPSR Art. 4, Art. 3(6), Art. 3(7) | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
| Who counts as manufacturer, authorised representative, importer, distributor and fulfilment service provider (postal services excluded); selling under your own name or trademark makes you the manufacturer | GPSR Art. 3(8), Art. 3(9), Art. 3(10), Art. 3(11), Art. 3(12), Art. 13(1) | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
| Regular checks with documented evidence on request; the tasks come on top of other businesses' duties; the manufacturer keeps the risk analysis and technical documentation | GPSR Art. 16(2), Art. 9(2) | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
| Accident notification when the manufacturer is outside the EU | GPSR Art. 20(4) | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
| Label information: Responsible Person, manufacturer, product identifier, instructions and safety information; digital formats such as a QR code only in addition | GPSR Art. 16(3), Art. 9(5), Art. 9(6), Art. 9(7), Art. 21 | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
| What every online offer must show, including the responsible person when the manufacturer is outside the EU | GPSR Art. 19 | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
| The importer's own contact details and documentation duty; the authorised representative's copy of the mandate for authorities | GPSR Art. 11(3), Art. 11(6), Art. 10(2) | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
| Marketplace duties: listing fields for traders, removal of dangerous offers on authority order, suspension of frequent offenders after a warning | GPSR Art. 22(9), Art. 22(4), Art. 22(11) | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
| Penalties are set by each EU country and must be effective, proportionate and dissuasive | GPSR Art. 44(1), Art. 44(2) | Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026 |
This guide is general information, not legal advice: it helps you work out which route applies to you and what evidence to keep, but it does not replace product-specific legal advice or an authority decision.
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