EU Responsible Person Under GPSR Article 16 (2026 Guide)
A GPSR EU Responsible Person is the EU-based business that takes on the tasks in Article 16 of the GPSR for a product. It is not automatically a consultant you hire separately. Depending on your supply chain, the role is held by the EU manufacturer, the importer, an authorised representative with a written mandate or, as a last resort, a fulfilment service provider.
Who needs an EU Responsible Person?
Every product within GPSR scope needs an economic operator established in the EU before it is placed on the Union market. For a manufacturer outside the EU, the correct operator depends on the actual supply chain and any written mandate; the manufacturer does not always need to buy a separate Responsible Person service.
| Supply-chain situation | Who holds the role | What decides the route? |
|---|---|---|
| Manufacturer is established in the EU | EU manufacturer | The manufacturer itself is the EU-established operator. |
| Manufacturer is outside the EU and an EU importer places the product on the market | EU importer | The importer is one of the operators the law allows for that product. |
| Non-EU manufacturer gives an EU entity a written mandate for the responsible-person tasks | Authorised representative | The written mandate must identify the tasks performed on the manufacturer's behalf. |
| No EU manufacturer, importer or authorised representative exists, but an EU fulfilment provider handles the product | Fulfilment service provider | This is the statutory fallback for the products the provider handles. |
An online marketplace does not become the responsible person just because the product is listed there. The product, product-specific EU law, importer arrangement and fulfilment chain must be checked together.
What does the GPSR Responsible Person actually do?
The responsible person is the contact point for documents, authorities and corrective action. Appointing one does not move the manufacturer's duties to design a safe product, carry out the risk analysis or keep the technical documentation.
| Legal task | What it means in practice | Which law |
|---|---|---|
| Verify that required records have been drawn up | Check that the applicable technical documentation exists and, where product-specific law requires it, that the EU Declaration of Conformity or performance has been drawn up. | EU market surveillance regulation |
| Make evidence available | Keep the applicable declaration available and ensure the technical documentation can be supplied to market-surveillance authorities on request. | EU market surveillance regulation |
| Report a product risk | Inform market-surveillance authorities when there is reason to believe the product presents a risk. | EU market surveillance regulation |
| Cooperate on corrective action | Work with authorities so non-compliance is corrected immediately or the product risk is mitigated. | EU market surveillance regulation |
| Perform GPSR-specific checks | Where appropriate for the product risks, regularly check the product against the technical documentation and the GPSR rules on product identification, manufacturer contact details, instructions and safety information. | GPSR |
| Keep evidence of those checks | Provide documented evidence of these checks when an authority requests it. | GPSR |
The German Federal Environment Ministry's current GPSR FAQ adds: if the manufacturer is outside the EU, the responsible person reports product-safety accidents.
Where must EU Responsible Person details appear?
The GPSR requires the responsible person's name, registered trade name or registered trademark and contact details, including a postal and electronic address. These details go on the product, its packaging, the parcel or an accompanying document.
Online and other distance sales have an extra display rule. If the manufacturer is not established in the EU, the product offer must show the Responsible Person's name, postal address and electronic address clearly and visibly.
Is a Responsible Person the same as an authorised representative?
No. Responsible Person is the function a product needs. Authorised representative is one way to fill that function: the manufacturer gives an EU-based person a written mandate. An importer or a qualifying fulfilment service provider can hold the role instead, without becoming the manufacturer's authorised representative.
What should a real Responsible Person mandate contain?
A usable mandate is product-specific and should identify:
- the legal manufacturer and the EU entity accepting the mandate;
- the accepted products or product families and excluded products;
- the responsible-person tasks covered;
- document-access, language and response arrangements;
- label and online-offer use of the operator's details;
- accident, authority-request and corrective-action handling;
- termination, renewal and record-transfer rules.
An address-only offer that does not name the product scope, review the available records or accept authority work is not equivalent to a product-based responsible-person mandate.
How much does Grüner Baum's EU Responsible Person service cost?
Grüner Baum GmbH's annual plans start at €249 for one accepted low-risk product family, with unlimited SKUs within each accepted family. The published starter scope includes a written appointment as responsible person, initial risk analysis, weekly Safety Gate monitoring and one authority correspondence per contract year.
For what the rest of the market publishes, a sourced survey of ten providers' own published prices — each read on 12 September 2026, with the pricing unit beside every figure — is in the EU Responsible Person cost guide. The units differ enough that the headline numbers are not directly comparable.
Grüner Baum checks the manufacturer, supply chain, product scope, available technical records, labels and online-offer information before accepting a mandate. The service is not a product certificate and does not guarantee marketplace, customs or authority approval. Review the EU Responsible Person service and comparison table or send the product scope for assessment.
Frequently asked questions about the EU Responsible Person
Does every non-EU manufacturer have to hire a third-party Responsible Person?
No. Every product within GPSR scope needs an EU-based economic operator for the responsible-person tasks, but that operator may already be the EU importer. A separately mandated authorised representative is one possible route, not an automatic requirement in every supply chain.
Who can be the GPSR Responsible Person?
The role can be held by an EU-based manufacturer, an importer where the manufacturer is outside the EU, an authorised representative with a written mandate, or an EU fulfilment service provider when none of the first three is established in the EU.
What does a GPSR Responsible Person check?
It checks that the required technical documentation exists. Where the product risks make it appropriate, it also regularly checks the product against that documentation and against the rules on product identification, manufacturer contact details, instructions and safety information.
Where must Responsible Person details appear?
The name or registered trade name or trademark, postal address and electronic address go on the product, packaging, parcel or an accompanying document. If the manufacturer is outside the EU, the details must also be shown in the online or other distance-sale offer.
How much does Grüner Baum's EU Responsible Person service cost?
Grüner Baum GmbH's published annual plans start at €249 for one accepted low-risk product family, with unlimited SKUs within each accepted family. Product scope and records are reviewed before a mandate is accepted.
Official sources
| Topic | Legal basis | Official text |
|---|---|---|
| A product needs an EU-based economic operator before it is placed on the market | GPSR Article 16(1) | Regulation (EU) 2023/988 on EUR-Lex |
| Who can hold the role and in which order: manufacturer, importer, authorised representative, fulfilment service provider | Regulation (EU) 2019/1020, Article 4(2), applied through GPSR Article 16(1) | Regulation (EU) 2019/1020 on EUR-Lex |
| Written mandate of the authorised representative | Regulation (EU) 2019/1020, Article 4(2)(c) | Regulation (EU) 2019/1020 on EUR-Lex |
| Verify documents, keep them available, report risks, cooperate on corrective action | Regulation (EU) 2019/1020, Article 4(3)(a) to (d) | Regulation (EU) 2019/1020 on EUR-Lex |
| Regular GPSR checks against the technical documentation and the identification, contact, instruction and safety-information rules; evidence on request | GPSR Article 16(2), referring to Article 9(2) and Article 9(5) to (7) | Regulation (EU) 2023/988 on EUR-Lex |
| Responsible person details on the product, packaging, parcel or accompanying document | GPSR Article 16(3) | Regulation (EU) 2023/988 on EUR-Lex |
| Responsible person details in online and distance-sale offers when the manufacturer is outside the EU | GPSR Article 19, point (b) | Regulation (EU) 2023/988 on EUR-Lex |
| Accident reporting by the responsible person when the manufacturer is outside the EU | GPSR Article 20(4); German Federal Environment Ministry GPSR FAQ | Regulation (EU) 2023/988 on EUR-Lex; German Federal Ministry: GPSR duties of the Responsible Person |
| The manufacturer keeps its duties for safe design, risk analysis and technical documentation | GPSR Article 9 | Regulation (EU) 2023/988 on EUR-Lex |
This article is general information, not legal advice.
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