What Must a GPSR Authorised Representative Mandate Contain?

As of 24 September 2026, a gpsr authorised representative mandate should be written, explicit, and product-specific. If you use an authorised representative as the EU economic operator for GPSR Article 16, the mandate should clearly identify the parties, the covered products, the tasks under Regulation (EU) 2019/1020 Article 4(3), the document flow, the duration, and the rules for using the representative’s address.

Why must a gpsr authorised representative mandate be written and product-specific?

Yes: if an authorised representative is the Article 16 economic operator for your consumer product, the mandate should be written and tied to defined products or product families, not left as a general commercial understanding.

The legal reason starts with GPSR Article 16. Since 13 December 2024, the GPSR has applied and replaced Directive 2001/95/EC. Under GPSR Article 16, a product may only be placed on the EU market if an economic operator established in the EU is responsible for the tasks in Regulation (EU) 2019/1020 Article 4(3). That operator can be the EU manufacturer, the importer, an authorised representative with a written mandate, or, in defined cases, a fulfilment service provider.

For non-EU sellers, that means two important things:

1. Not every seller needs a separate service. If your EU importer or EU manufacturer already performs the Article 16 role, a separate authorised representative mandate may not be necessary.
2. If you do use an authorised representative, the mandate should prove exactly what was accepted. Authorities and sales channels do not assess vague intentions; they assess evidence.

The mandate also needs to be product-specific because scope matters. Under GPSR Article 4, online offers targeting EU consumers count as making products available on the EU market. If a listing goes live for EU buyers, the economic operator information shown there should match a real Article 16 arrangement for that product. A blanket letter that does not identify the products, product family, or manufacturer does not show that the representative actually accepted responsibility for the item being sold.

This is why a serious mandate is usually scoped to an accepted product family, supported by the documents reviewed for that family. That approach is also practical for businesses selling many SKUs: the representative can accept a defined family, while still requiring review when the risk profile, documents, or product identity changes.

If you want the wider legal background first, see our EU Responsible Person service and why the Responsible Person is critical.

Which clauses must every gpsr authorised representative mandate contain?

Every GPSR mandate should contain enough detail to show who appointed whom, for which products, for which Article 16 tasks, for what period, with what document flow, and under what address-use conditions.

The checklist below is not a contract template. It is the minimum clause logic that helps show whether the arrangement is real, accepted, and usable as evidence.

Two practical points matter here.

First, the mandate should be explicit, not implied. A shipping arrangement, a general reseller agreement, or a listing account approval is not the same thing as a written Article 16 mandate.

Second, the mandate should be usable as evidence. Market surveillance authorities differ by Member State and product law, but they can check whether the operator information shown to consumers matches a real mandate and whether the underlying products were within accepted scope.

What must the manufacturer deliver to the representative?

The manufacturer should deliver a complete evidence pack, because an authorised representative cannot sensibly accept Article 16 scope without reviewing the product identity, safety documents, and the way the operator information will be shown.

In practice, the representative will usually need the following before acceptance:

1. Manufacturer identity details
   Provide the exact legal entity name, registered address, operating contact, and the entity that actually manufactures the product. If a trading company and a factory are different entities, say so clearly.

2. Product scope details
   Provide product descriptions, photos, brand names used on the product, SKU examples, and the proposed grouping into product families. If you sell variations, explain what changes between them and what stays the same.

3. Technical documentation and safety evidence
   Provide the product file needed for the product type: design and material information, safety assessment or risk assessment, instructions, warnings, traceability details, and any available test reports or declarations where required. For a deeper overview of typical file contents, see our GPSR technical documentation guide.

4. Label and online listing drafts
   Provide the exact operator details, product warnings, and manufacturer information as they will appear on packaging, labels, instruction material, and distance-selling pages. This is important because GPSR Article 19 sets information duties for distance sales. See also our guide to GPSR online sales information and our labelling requirements guide.

5. Sales-channel and market information
   Provide where the products will be sold: your own online store, a marketplace, or both, and which EU countries you target. Because online offers targeting EU consumers count under GPSR Article 4, channel information matters before launch, not after.

6. Change and incident contact process
   Provide the person who will answer document requests, safety questions, and incident escalations. If a product issue appears, the representative should know how to reach the manufacturer quickly.

A representative should also know what is not being accepted. For example, a mandate for one accepted low-risk product family does not automatically cover a new family with a different risk profile. Likewise, acceptance of a label layout for one family does not mean every later product or brand variant can show the same address.

This is also where many applications fail: the business sends a short appointment request, but not the underlying product evidence. Under GPSR Article 16 and Regulation (EU) 2019/1020 Article 4(3), the representative role is evidence-based, not just administrative.

Can you use the representative’s address before and after acceptance?

You should not use the representative’s address on the product, packaging, or online listing before the mandate has been accepted for that product scope. After acceptance, you may use it only for the accepted products and only in the agreed format.

This point is simple but often mishandled. Displaying a provider’s address on a label or listing without an accepted mandate is not a valid Article 16 arrangement. If authorities ask who the EU economic operator is, the business should be able to show the underlying written mandate and the product scope it covers.

Because online offers to EU consumers count as making products available on the EU market under GPSR Article 4, the same rule matters for ecommerce pages. If the listing shows operator information, that information should be backed by a real mandate.

A practical rule is this: no acceptance, no address use.

That rule reduces confusion for your team, your packaging supplier, and your ecommerce staff. It also helps keep the operator information shown under GPSR Article 19 aligned with the actual Article 16 arrangement.

When must the mandate be updated for new products, brands or sales channels?

You should update or re-review the mandate whenever a change affects product identity, product scope, responsible entity, or the operator information shown to EU consumers.

The most common triggers are these:

1. You add a new product family
   If the new item is outside the already accepted family, treat it as new scope. Even if the commercial category sounds similar, the safety evidence may differ.

2. You change the manufacturer entity
   If a new legal entity becomes the manufacturer, the existing mandate may no longer identify the right party. The written mandate should match the actual manufacturer.

3. You introduce a new brand or materially different label presentation
   If the product identity shown to consumers changes, the representative should re-check whether the address use, traceability, and product identification still match the accepted evidence.

4. You change the listing channel or listing content
   A new marketplace, a new store, or a different listing template may change what operator information is shown online. Because GPSR Article 19 applies to distance sales, this should be checked before launch.

5. The product documents change
   New materials, new warnings, new instructions, revised test evidence, or a new risk assessment can all affect whether the original mandate still reflects the real product.

A useful decision test is:

• Same manufacturer
• Same accepted product family
• Same safety profile
• Same operator information format
• Same supporting documents, or documents updated and reviewed

If one of those points changes materially, ask for a scope review before using the address on new offers or new packaging.

This is especially important for sellers with fast-moving catalogues. It is tempting to think that one accepted mandate covers all future SKUs forever. In reality, the stronger approach is controlled scope plus documented updates.

How can Grüner Baum help with a gpsr authorised representative mandate?

Grüner Baum helps by reviewing whether your requested Article 16 arrangement is documented, scoped, and operationally usable before its address is used for EU sales.

As of 17 September 2026, the annual service options are:

• Starter — €249/year for 1–3 accepted low-risk product families, with unlimited SKUs within each accepted family
• Business — €549/year for up to 5 accepted low-risk product families
• Growth — €949/year for up to 20 accepted low-risk product families
• Enterprise — €1,650+/year for more than 20 product families, multiple brands, or a wide product catalogue

Across those plans, the service includes the EU Responsible Person / Article 16 mandate, technical documentation verification, a risk + document-gap review, initial label / online-listing review for the accepted family scope, weekly Safety Gate monitoring, and authority and initial incident-response support. That is important for mandate quality, because a valid appointment is not only about signing a document; it is also about whether the representative has enough evidence to accept the scope.

Optional services, as of 17 September 2026, include:

• 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 boundaries also matter. Grüner Baum does not certify products, does not guarantee marketplace approval, and 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 want a mandate review linked to actual product scope and document checks, start with our EU Responsible Person service, review the pricing information, or contact Grüner Baum.

Frequently asked questions about gpsr authorised representative mandate

Do I need a written mandate for a GPSR authorised representative?

Yes. If you use an authorised representative as the EU economic operator for GPSR Article 16, the mandate should be written and explicit, so the accepted scope and Article 4(3) tasks can be evidenced.

Can I put the representative's EU address on my label before approval?

No. The address should only be used after the representative has accepted the mandate for the relevant products; showing it earlier does not create a valid Article 16 arrangement.

Must the mandate list products or product families?

Yes. The mandate should define the covered products clearly enough to show what is in scope and what is outside scope, often by accepted product family supported by product evidence.

What documents must I send with the mandate request?

You normally need manufacturer identity details, product descriptions, label and listing drafts, technical documentation, safety information, instructions and warnings, and any relevant test reports or declarations.

When do I need to update a GPSR mandate?

You should update or re-review it when the manufacturer entity changes, when you add products outside accepted scope, when branding or label presentation changes materially, or when a new channel changes the information shown to EU consumers.

Does marketplace approval replace the written mandate?

No. Marketplace approval is not the same as the written mandate behind an Article 16 arrangement, and authorities can still check whether the underlying mandate and product scope are valid.

Official sources

• Regulation (EU) 2023/988 (GPSR), consolidated text of 29 May 2026
• Regulation (EU) 2019/1020, consolidated text of 12 August 2026
• European Commission GPSR guidance for businesses (C/2025/6233)
• European Commission GPSR questions and answers

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