What Must a GPSR Authorised Representative Mandate Contain?

A GPSR authorised representative mandate should be written, explicit, and product-specific. If an authorised representative is your responsible economic operator in the EU, the mandate should clearly name the parties, the covered products, the tasks the representative takes on, 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 responsible economic operator in the EU for your consumer product, the mandate should be written and tied to defined products or product families. A general commercial understanding is not enough.

The legal reason starts with the GPSR’s rule on the responsible person. The GPSR has applied since 13 December 2024 and replaced the old General Product Safety Directive. Under the GPSR, a product may only be placed on the EU market if an economic operator based in the EU is responsible for the tasks set out in the EU market surveillance regulation. 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 fills the responsible-person role, you may not need a separate authorised representative mandate.
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 the GPSR, online offers aimed at EU consumers count as making products available on the EU market. So when a listing goes live for EU buyers, the operator details shown there should match a real arrangement for that product. A blanket letter that does not name 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 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 as a written mandate for the responsible-person role.

Second, the mandate should be usable as evidence. Market surveillance authorities differ by EU country and product law. But they can check whether the operator details shown to consumers match a real mandate and whether the products were within the accepted scope.

What must the manufacturer deliver to the representative?

The manufacturer should deliver a complete evidence pack. An authorised representative cannot sensibly accept the responsible-person role for a product without reviewing the product identity, the safety documents and how the operator details 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 matters because the GPSR sets information duties for online and other 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 aimed at EU consumers count under the GPSR, 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 product evidence behind it. Under the GPSR and the market surveillance regulation, the representative role is based on evidence, not just paperwork.

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. Showing a provider’s address on a label or listing without an accepted mandate is not a valid arrangement. If authorities ask who the EU economic operator is, the business should be able to show the written mandate and the product scope it covers.

Online offers to EU consumers count as making products available on the EU market under the GPSR. So the same rule matters for ecommerce pages. If the listing shows operator details, a real mandate should back them up.

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 keeps the operator details shown in your online offers in line with the actual mandate.

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 the GPSR’s online-offer rules apply to distance sales, check this 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 arrangement is documented, scoped, and operationally usable before its address is used for EU sales.

The annual service options are:

• Starter — €249/year for 1 accepted low-risk product family, 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 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 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 an authorised representative is your responsible economic operator in the EU, the mandate should be written and explicit. It should name the manufacturer, the EU representative, the covered products or product families and the tasks the representative takes on. That way you can prove the arrangement to authorities and sales channels.

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

No. Showing an EU address on a label, package or online listing before the mandate is accepted does not create a valid arrangement. Use the address only after the representative has accepted the scope, and only for the products that the accepted mandate covers.

Must the mandate list products or product families?

Yes. The mandate should define the product scope clearly enough to show what is covered and what is not. In practice this is often done by accepted product family, with unlimited SKUs only inside that family, backed by product descriptions and technical documents.

What documents must I send with the mandate request?

You normally provide the manufacturer's identity details, product descriptions, label and listing drafts, technical documentation, risk information, instructions and warnings, and any test reports or declarations the product type needs. The representative uses this evidence to decide whether it can accept the requested scope.

When do I need to update a GPSR mandate?

Update it or ask for a new review when the manufacturer entity changes, when you add products outside the accepted family, when a new brand or label format changes how the product is identified, or when a new sales channel changes the operator details EU consumers see. A mandate is not a blanket approval for all future products.

Does marketplace approval replace the written mandate?

No. A marketplace's acceptance or listing approval does not replace the written mandate behind an authorised-representative arrangement. Authorities can still check whether a valid mandate exists and whether the products shown online fall within its accepted scope.

Official sources

This guide is general information, not legal advice; it does not replace a product-specific legal analysis or an authority decision.