# EU authorised representative vs Responsible Person (2026)

> EU authorised representative under GPSR is the mandated Article 16 route if no EU manufacturer or importer covers you.

Published: 2026-09-21
Updated: 2026-09-21

Canonical page: [https://eugpsr.de/en/blog/eu-responsible-person-vs-authorised-representative](https://eugpsr.de/en/blog/eu-responsible-person-vs-authorised-representative)

As of 21 September 2026, an EU authorised representative is **not automatically required** for every non-EU seller under GPSR. What you do need is an EU-established economic operator for the product under GPSR Article 16, and that can be the EU manufacturer, the importer, an authorised representative with a written mandate, or, in defined cases, a fulfilment service provider. In everyday market language, many sellers call this an “EU Responsible Person”, but for the mandate route in GPSR the legal term is **authorised representative**.

If you sell consumer products into the EU from outside the EU, this distinction matters because the correct route depends on your sales model, your stock flow, and whether an importer already exists. If your own web shop or listing targets EU consumers, that offer counts as making the product available on the EU market under GPSR Article 4, so the Article 16 question arises early, not only after a customs or marketplace issue appears. For the basics of the regulation itself, see [our GPSR overview](https://eugpsr.de/en/what-is-gpsr).

## Is "EU Responsible Person" the same as "authorised representative"?

In GPSR language, **“EU Responsible Person” is market wording, not the main legal term for the mandate route**. Under GPSR Article 16(1), the mandated route is an **authorised representative with a written mandate**. So the two phrases often point to the same commercial service, but they are not interchangeable in every legal context.

That difference matters because “Responsible Person” is also used in other product laws, especially cosmetics, and “authorised representative” is also used in CE-sector frameworks. If a seller simply asks for a “Responsible Person” without checking the legal basis, they may end up with the wrong document set or the wrong scope.

| Term you hear | What it usually means in practice | Legal basis to check | Key evidence point |
|---|---|---|---|
| EU Responsible Person | Market wording for the EU operator needed for non-EU sales | GPSR Article 16 | Confirm which Article 16 route is actually being used |
| Authorised representative | The mandate-based Article 16 route | GPSR Article 16(1) | A **written mandate** is required |
| Cosmetics Responsible Person | Product-specific role for cosmetics | Cosmetics law, not GPSR | Do not assume a GPSR mandate covers cosmetics |
| CE authorised representative | Role used in harmonised product frameworks | Sector rules and Regulation (EU) 2019/1020 context | Do not assume the same mandate scope unless stated |

Two practical points follow from this:

1. **Not every non-EU seller needs to buy a separate mandate.** If an EU importer or EU manufacturer already covers the product, that may already satisfy GPSR Article 16.
2. **You should not use an authorised representative’s address without written acceptance.** Grüner Baum acts under a written, product-family-scoped mandate, and its address may not be used without that written acceptance.

If you want a deeper explanation of why the operator role matters for access to the EU market, see [our guide to the Responsible Person role](https://eugpsr.de/en/blog/why-responsible-person-critical).

## What are the four GPSR Article 16 routes?

GPSR Article 16 accepts **four possible routes**. The right question is not “Do I need a Responsible Person?” but **“Which Article 16 operator covers this product?”**

The regulation says a product may only be placed on the EU market if there is an economic operator established in the EU responsible for the tasks in Regulation (EU) 2019/1020 Article 4(3). Under GPSR Article 16, that operator can be:

1. **The manufacturer**, if the manufacturer is established in the EU.
2. **The importer**, if an EU importer places the product on the EU market.
3. **An authorised representative**, if there is a written mandate.
4. **A fulfilment service provider**, in defined cases.

This means the mandate route is only **one** of the four possible routes. It is common for direct-to-consumer sellers outside the EU because they often have **no EU importer** and **no EU establishment** of their own.

| Article 16 route | When it usually applies | Is a written mandate needed? | Main risk if misunderstood |
|---|---|---|---|
| EU-established manufacturer | The manufacturer itself is in the EU | No | Non-EU brand assumes this applies when it does not |
| Importer | An EU business imports and places the product on the EU market | No separate AR mandate for that route | Seller thinks customs broker or platform is the importer |
| Authorised representative | Non-EU seller or manufacturer appoints an EU operator | **Yes** | Seller uses an address without a valid mandate |
| Fulfilment service provider | Defined cases where no EU manufacturer, importer or AR exists | Not an AR mandate route | Seller assumes warehousing automatically solves Article 16 |

Evidence still matters whichever route you use. The manufacturer remains responsible for product safety under GPSR Article 9, and must operate internal product-safety processes under GPSR Article 14. Article 16 does not transfer the whole legal burden away from the manufacturer.

## Which route applies to your sales model?

Your sales model usually determines the first answer. If goods move through an EU importer, the importer route may work. If you sell direct from outside the EU to EU consumers, a written authorised representative mandate is often the cleanest route unless another Article 16 operator clearly exists.

The following decision table covers the common cases non-EU exporters and online sellers ask about:

| Sales route | Who is usually the Article 16 operator? | Is a mandate needed? | Evidence to confirm |
|---|---|---|---|
| EU importer buys the goods and places them on the EU market | **Importer** | Usually **no** separate AR mandate | Contract chain, importer identity, label/listing details |
| Own web shop ships from outside the EU directly to EU consumers | Usually **authorised representative** unless another EU operator exists | Usually **yes** | Written mandate, product-family scope, documentation availability |
| Marketplace listing with stock outside the EU | Usually **authorised representative** unless an EU importer is actually in the chain | Usually **yes** | Do not assume the marketplace is your operator; check the supply chain |
| Stock held in an EU fulfilment centre | **Fulfilment service provider** only in defined cases, otherwise importer or authorised representative | **Not for the FSP route itself**, but you still need a valid Article 16 route | Who imports, who stores, who accepts the operator role, and whether the provider qualifies |

Three recurring mistakes appear here.

First, sellers confuse **targeting EU consumers** with merely having a website. Under GPSR Article 4, if the offer targets EU consumers, it counts as making available on the EU market.

Second, sellers assume a marketplace will become their operator. Marketplaces have duties under GPSR Article 22, but that does **not** automatically make them your Article 16 operator.

Third, sellers believe an EU warehouse by itself solves the issue. It does not. You still need to identify which legal route applies and whether the warehouse provider actually falls within the defined fulfilment-service-provider route.

For the information that must appear in distance sales, see [our guide to GPSR online sales information](https://eugpsr.de/en/blog/gpsr-online-sales-required-info).

## Cosmetics Responsible Person and CE authorised representative: are they the same thing?

No. The same words are used across different frameworks, but **the legal role depends on the product law**. A cosmetics Responsible Person is not the same as a GPSR Article 16 operator, and a CE-sector authorised representative is not automatically the same as a GPSR authorised representative.

This is one of the most expensive terminology mistakes because companies often assume that one existing appointment letter solves every regime. It usually does not.

For **cosmetics**, the Responsible Person comes from a product-specific regulation and follows a different compliance logic. GPSR can still be relevant around general product-safety interactions, but cosmetics are not handled simply by reusing a generic GPSR mandate. See [our cosmetics and GPSR guide](https://eugpsr.de/en/blog/cosmetics-regulation-gpsr) for that distinction.

For **CE-sector goods**, an authorised representative may already exist under the relevant harmonised framework. The name is the same, but the scope may differ. One written mandate can cover both GPSR and CE-related tasks **only if the mandate expressly says so**. If the text is narrow, authorities or marketplaces may treat the coverage as incomplete.

A practical check is simple:

- Read the current mandate.
- Confirm the product families covered.
- Confirm whether GPSR Article 16 is named.
- Confirm whether any CE-related scope is also named.
- Do not rely on assumptions based on a label template alone.

## What must the mandated operator actually do under Regulation (EU) 2019/1020 Article 4(3)?

The mandated operator is **not a decorative address service**. The Article 16 operator must be able to perform the tasks listed in Regulation (EU) 2019/1020 Article 4(3): verify documentation exists, keep it available for authorities, provide information on request, inform about risks, and cooperate on corrective action.

That is why a serious mandate process asks for evidence before acceptance. If the operator cannot show those basics, the route is weak when an authority, customs channel, or marketplace asks questions.

| Task under Regulation (EU) 2019/1020 Article 4(3) | What it means in practice | Common mistake |
|---|---|---|
| Verify that the EU declaration of conformity or technical documentation exists, where required | The operator checks that the relevant file exists for the product family | Sending only product photos or a listing URL |
| Keep documentation available for authorities | The file must be retrievable and linked to the covered products | Assuming the manufacturer can “send it later” |
| Provide information and documentation on request | Authorities may ask for evidence in a language or format they can review | Confusing marketing claims with technical evidence |
| Inform authorities if the product presents a risk | Risk escalation cannot wait for a sales problem to become public | Treating incidents as customer-service issues only |
| Cooperate on corrective action | Corrective action may include warnings, withdrawal, or recall support | Believing Article 16 removes the manufacturer’s duties |

The manufacturer still keeps the core legal responsibility for product safety and evidence quality. GPSR Article 9 sets manufacturer obligations. GPSR Article 14 requires internal product-safety processes. If a product must be recalled, notice and remedy obligations sit within the wider GPSR system, including GPSR Articles 36 and 37. Member State penalties are set nationally under GPSR Article 44.

For many sellers, the practical implication is this: an authorised representative can support the Article 16 route, but it does **not** certify the product and does **not** replace the manufacturer’s responsibility.

If you are still assembling your file, [our guide to technical documentation contents](https://eugpsr.de/en/blog/gpsr-technical-documentation-contents) helps explain what evidence is typically expected.

## What evidence should you have ready before choosing an EU authorised representative?

Before you ask for a mandate, you should prepare the product and company evidence that an Article 16 operator will need to review. This reduces delays and makes it easier to decide whether your case fits the importer route, the mandate route, or another route.

A practical preparation sequence is:

1. **Map the supply chain.** Identify whether an EU manufacturer or importer already exists for the exact product flow.
2. **Define the product family.** Group variants that truly belong together; acceptance is normally scoped by product family, not by vague catalog language.
3. **Collect technical documents.** Have the available technical file, test evidence, specifications, warnings, instructions, and traceability information ready.
4. **Prepare label and listing drafts.** Distance sales information under GPSR Article 19 must line up with the operator route you actually use.
5. **Disclose known risks or incidents.** Prior complaints, hazard questions, or design changes matter to the review.
6. **Wait for written acceptance before using details.** Do not print or publish an operator address before the mandate is accepted in writing.

This is also the point where some businesses discover that they have become the **manufacturer** for legal purposes in a specific case, for example after substantial modification or relabelling scenarios covered by GPSR Article 13. That changes the evidence burden and should be checked early.

## How can Grüner Baum help with EU authorised representative mandates?

Grüner Baum acts as an authorised representative under a **written, product-family-scoped mandate** for accepted low-risk product families. The service is designed for companies outside the EU that need a clear Article 16 route and documented review before using an EU operator address.

As of **17 September 2026**, the published options are:

| Plan | Scope | Annual price | Included for accepted families |
|---|---|---:|---|
| **Starter** | 1–3 accepted low-risk product families | €249/year | Article 16 mandate, unlimited SKUs within each accepted family, technical documentation verification, risk + document-gap review, initial label / online-listing review for each accepted family, weekly Safety Gate monitoring, authority and initial incident-response support |
| **Business** | Up to 5 accepted low-risk product families | €549/year | Same core mandate scope, plus 5 initial label / online-listing reviews |
| **Growth** | Up to 20 accepted low-risk product families | €949/year | Same core mandate scope, plus 20 initial label / online-listing reviews |
| **Enterprise** | More than 20 product families, multiple brands or a wide product catalogue | €1,650+/year | Same core mandate scope with dedicated service level and communication process |

Optional services published as of 17 September 2026 are:

- **Formal Technical Documentation Audit & Written Gap Report** — €129 / product family
- **24-hour Priority Onboarding Review** — €99 / company
- **Extended Authority Support** — €125 / hour
- **Extended Product Recall Management** — from €750 / project

Two limits are important. First, the service is **not a certificate** that a product is automatically safe or compliant with all legislation, and it does not guarantee marketplace approval. Second, Grüner Baum does not replace the manufacturer’s legal responsibility; the manufacturer remains responsible for product safety and for the accuracy and completeness of the information provided.

If you need a mandate-based Article 16 route, the next step is to send your product-family scope, sales model, and current documentation set through [our contact page](https://eugpsr.de/en/contact).

## Frequently asked questions about eu authorised representative

### Do I always need an EU authorised representative to sell to the EU?

No. GPSR Article 16 requires an EU-established economic operator, but that operator can be the EU manufacturer, the importer, an authorised representative with a written mandate, or, in defined cases, a fulfilment service provider. You need a separate authorised representative only if none of the other Article 16 routes already covers the product.

### Is an importer the same as the GPSR Article 16 operator?

Often yes, but not always in the practical sense sellers assume. If an EU importer places the product on the EU market, that importer can be the Article 16 economic operator. If you sell direct from outside the EU without an importer, you usually need another Article 16 route, commonly an authorised representative with a written mandate.

### Does a marketplace become my Responsible Person under GPSR?

No, not by default. Online marketplaces have their own duties under GPSR Article 22, but those duties do not automatically make the marketplace your Article 16 operator. If you target EU consumers from outside the EU, you still need a valid Article 16 route for the product.

### Can one mandate cover both GPSR and CE-related authorised representative tasks?

Sometimes, but only if the written mandate clearly says so. The GPSR Article 16 route and a CE-sector authorised representative role may use the same words, yet they do not automatically have the same scope. A document written for one framework should not be assumed to cover the other unless the mandate text expressly includes both.

### Can I use an authorised representative's address on my label before approval?

No. An authorised representative's details should only be used after written acceptance and a valid mandate for the relevant product family. Using an address without written acceptance creates evidence problems and can trigger questions from marketplaces or market surveillance authorities.

### What documents should be ready before applying for an authorised representative mandate?

You should have the manufacturer identity, product-family description, available technical documentation, risk information, traceability details, and current label and online listing drafts ready. The Article 16 operator must be able to verify that required documents exist and provide information to authorities on request, so incomplete files usually delay acceptance.

## Official sources

- [Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026](https://eur-lex.europa.eu/eli/reg/2023/988/2026-05-29/eng)
- [Regulation (EU) 2019/1020, consolidated text of 12 August 2026](https://eur-lex.europa.eu/eli/reg/2019/1020/2026-08-12/eng)
- [European Commission GPSR guidance for businesses (C/2025/6233)](https://eur-lex.europa.eu/eli/C/2025/6233/oj/eng)
- [European Commission GPSR questions and answers](https://webgate.ec.europa.eu/safety/consumers/consumers_safety_gate/obligationsForBusinesses/documents/Q%26A.pdf)
- [Safety Gate portal (EU rapid alert system)](https://ec.europa.eu/safety-gate/)

This guide supports scope and evidence diagnosis. It does not replace product-specific legal analysis or an authority decision.