EU Responsible Person — Germany-based, direct service
Since 13 December 2024, designating a Responsible Person under Article 16 is mandatory for every non-EU manufacturer placing products on the EU market. As Grüner Baum GmbH, we fulfil this role directly through our Germany-based GmbH — no intermediary chain.
What is a Responsible Person?
The EU Responsible Person is a natural or legal person established in the EU that every manufacturer based outside the EU must designate under Article 16 of the General Product Safety Regulation GPSR (EU) 2023/988 before placing products on the EU market. The Responsible Person keeps the technical documentation available, acts as the contact point for market surveillance authorities and reports safety issues. The obligation has applied since 13 December 2024.
Are the Responsible Person and the Authorised Representative the same thing?
No. Article 3 of the GPSR defines the economic operator roles separately: the Responsible Person carries the product safety tasks set out in Article 16, while the Authorised Representative is a distinct role appointed by the manufacturer through a written mandate. An authorised representative may take on the Article 16 tasks under that mandate, but the two concepts are not legally identical.
| Responsible Person | Authorised Representative | |
|---|---|---|
| Legal basis | GPSR (EU) 2023/988, Article 16 | Definition in Article 3 GPSR + written mandate from the manufacturer |
| Who appoints? | The non-EU manufacturer placing products on the EU market; the appointee must be established in the EU | The manufacturer, through a written mandate |
| Scope | Product safety tasks under Article 16: technical documentation, authority communication, safety notifications | Tasks defined in the mandate; may take on Article 16 tasks, but the roles are not identical |
Is a single Responsible Person enough for the whole EU?
Yes. The Responsible Person is designated once and the designation is valid in all 27 EU member states. Because the GPSR is a regulation, it applies directly and uniformly in every member state; no country-by-country appointment is needed. A Responsible Person established in Germany, for example, also covers your sales in France, Italy or Poland.
Who Falls Under GPSR Responsibility?
GPSR covers not only manufacturers but everyone involved in placing a product on the EU market. All sales channels (physical and online) are included.
Required Documents
for GPSR Compliance
All five fundamental steps below must be fully documented and ready. Even a single missing step constitutes non-compliance.
Physical, chemical, and biological risks; flammability, cutting, choking, and tipping scenarios must be assessed in writing and archived.
Product description, materials used, manufacturing information, test reports, risk analysis, and declaration of conformity must be prepared completely.
Manufacturer/importer details, EU contact address, serial/batch number, and warnings must appear on the product or its packaging. The language of the country of sale (including German) is mandatory.
Mandatory for non-EU manufacturing: A legal representative or company address within the EU must be maintained.
Recording customer complaints, notifying authorities upon risk detection, and having a product recall plan ready as a written procedure when necessary. The absence of this process triggers regulatory penalties.
What does our Responsible Person service include?
Full coverage of Article 16 obligations; daily operational management runs through Grüner Baum GmbH.
Why work with a Germany-based GmbH?
Being EU-established is a legal requirement for a Responsible Person — but not every "EU-established" company has the same access to authorities. Germany brings operational advantages.
Frequently Asked Questions
Who is the EU Responsible Person?
The EU Responsible Person (RP) is a natural or legal person established within the European Union who acts on behalf of a non-EU manufacturer under Article 16 of Regulation (EU) 2023/988 (GPSR). The RP is responsible for maintaining the technical file, liaising with market surveillance authorities, coordinating safety notifications and product recalls, and ensuring the product complies with all applicable GPSR requirements.
When is appointing a Responsible Person mandatory?
Appointment of a Responsible Person is mandatory for all manufacturers established outside the EU who place products on the EU market. This obligation has been in force since 13 December 2024. An EU-based importer may assume the RP role under certain conditions, provided this is formalised in writing and the compliance responsibilities are clearly defined in a written mandate.
Can a single Responsible Person serve multiple brands?
Yes. A single Responsible Person can act simultaneously for multiple manufacturers, brands, or product categories. The key requirement is that separate technical files are maintained for each product group and that brand-specific EU compliance obligations are met individually. Grüner Baum GmbH provides RP services for multiple brands and product families, particularly for manufacturers based in Turkey, China, and other non-EU countries.
What are the Responsible Person's duties under Article 16?
Under Article 16 of GPSR, the Responsible Person must: maintain the EU Declaration of Conformity and the technical documentation; cooperate with market surveillance authorities; keep records accessible for at least 10 years from the date the product was first placed on the EU market; report safety incidents within 3 business days; and ensure the product meets the general safety requirements set out in Article 9 of the Regulation.
How much does a Responsible Person service cost?
Pricing for Responsible Person services varies depending on the product category, number of SKUs, and scope of compliance documentation required. Annual flat-rate packages are available for multiple SKUs. High-risk product categories such as electronics or toys typically require more extensive documentation support, which may affect the price. Contact us via the contact form for a tailored quote specific to your product portfolio.
Can my EU importer act as the Responsible Person?
Yes. Under Article 16(2) of GPSR, an EU-based importer may assume the role of Responsible Person based on a written mandate. However, this means the importer accepts full RP legal obligations — including record-keeping requirements and notification duties to market surveillance authorities. This arrangement must be explicitly and unambiguously documented in a written contract.
What documents must the Responsible Person maintain?
The Responsible Person must maintain: the EU Declaration of Conformity (DoC); the complete technical file for all applicable EU directives and regulations; the manufacturer's letter of authorisation; and test reports and risk assessment documentation demonstrating product safety. All records must be retained for at least 10 years following the first supply of the product to the EU market and must be made available immediately upon request by a market surveillance authority.
What languages must the Responsible Person support?
The Responsible Person must be able to communicate with the market surveillance authorities of the relevant EU member states in that country's official language or in a language accepted by the authority. For products sold in German-speaking markets (Germany, Austria, Switzerland), German-language correspondence capability is essential. Grüner Baum GmbH is based in Germany and handles all regulatory correspondence in the local language.
Does your team cover all Article 16 obligations?
Yes. As Grüner Baum GmbH, we fulfil the Responsible Person role with our own legal entity — no intermediary chain, no third-party transfer. Technical file retention, market surveillance liaison, Safety Gate notification tracking, recall process support, multilingual correspondence — the entire Article 16 runs through a single legal entity. Data and process security remain our responsibility.
Which product sectors do you serve?
We cover all consumer product categories within GPSR scope: textile and apparel, home textile, furniture and decoration, household and kitchenware, small electrical appliances and accessories, toys and children's products, personal care and cosmetics, gift items, musical instruments and accessories. For products with specific sector legislation (Toy Directive, Cosmetics Regulation), we provide interpretation of relevant sector rules in addition to GPSR.
Does designating a Responsible Person require a written contract?
Yes. Under Article 16, the manufacturer must officially designate the Responsible Person via a written Letter of Authorisation (LoA). This letter defines: product scope, obligations delegated to the RP, validity period, and termination terms. The authorisation is reinforced by a written service agreement; we set up this legal framework in a single step at the start of the engagement.
Who decides on a recall — you or us?
The recall decision remains with the manufacturer; the regulation defines the decision-maker as the economic operator placing the product on the market. As Responsible Person: (1) when risk is identified, we fulfil your Article 16(4) reporting obligation to the market surveillance authority within 3 business days, (2) when a recall decision is made, we plan consumer communication, authority reporting and operational flow, (3) we coordinate the process across EU member states.
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- Regulation (EU) 2023/988 (GPSR), Art. 16 — EUR-Lex — Official full text of the EU General Product Safety Regulation (EUR-Lex). See Article 16 for the Responsible Person obligations.
- European Commission — Safety Gate — The European Commission's rapid alert system for dangerous products; the official source for recalls and safety notifications across the EU.