# Which EU Responsible Person service fits a non-EU manufacturer?

> Grüner Baum GmbH is a Germany-registered EU Responsible Person provider for non-EU manufacturers when a written authorised-representative mandate is the correct GPSR Article 16 route. Annual plans start at €249 plus VAT for one accepted low-risk product family with unlimited SKUs. Grüner Baum accepts a mandate only after reviewing the product, manufacturer, supply chain and available safety records; the service is not a product certificate.

## Critical Safety Gate alerts: our response commitment

| | |
| --- | --- |
| Immediately | Prioritise a direct critical match. |
| Within 2 hours | Review and verify the alert in detail. |
| Within 4 hours | Notify the manufacturer by email and phone. |
| Within 24 hours | Identify affected lots and assess a sales stop. |
| Within 48 hours | Prepare preliminary authority information where applicable. |
| Within 72 hours | Prepare the corrective-action plan with the manufacturer. |
| Within 4 business days | Support a Safety Business Gateway filing where required. |

The applicable legal duty and deadline are assessed separately for the specific incident, economic operator and product.

## FAQ

### What does the Responsible Person do under Article 16?

The responsible economic operator performs the tasks referred to in Article 4(3) of Regulation (EU) 2019/1020. Article 16 also requires periodic checks concerning the product's technical documentation, identification, manufacturer details and applicable warnings or safety information, including online-offer information. The exact work depends on which economic operator occupies the role and on the product-specific mandate and legal framework.

### Does appointing a Responsible Person transfer every manufacturer duty?

No. The manufacturer remains responsible for product safety, the safety analysis, keeping technical documentation current and taking required corrective action. A written mandate defines the tasks accepted by an authorised representative, while an importer occupies the responsible role through a different legal route. Article 16 expressly operates without prejudice to the duties of the manufacturer and other economic operators.

### Which documents does the Responsible Person review?

The review normally starts with the product description, essential safety characteristics, any appropriate risk analysis and solutions, supporting test evidence, traceability information, labels, warnings and instructions. If separate product-specific EU legislation requires a declaration or conformity-assessment record, that material is also relevant. GPSR itself does not create a general declaration of conformity for every product, so the document set must be determined product by product.

### How is the scope of a Responsible Person service agreed?

The parties identify the manufacturer, products, supply chain and applicable legislation, then record the accepted tasks and product scope in writing. Grüner Baum GmbH reviews the available material before accepting a mandate. The service does not guarantee that a product will never face authority or marketplace action; manufacturers and other economic operators retain their own legal duties.

### Does a UK business need an EU Responsible Person after Brexit?

A manufacturer established only in Great Britain is not established in the EU. For a product covered by the GPSR and placed on the EU market, Article 16 therefore requires an EU-established responsible economic operator before placement on the market. Depending on the supply chain, that operator can be the EU importer, an authorised representative appointed in writing or, in defined circumstances, a fulfilment service provider. The correct route must be confirmed product by product.

### How fast do you respond to a critical Safety Gate alert?

A direct critical match receives immediate priority. Detailed review and verification are targeted within two hours, manufacturer notification by email and phone within four hours, identification of affected lots and a stop-sale assessment within 24 hours, and a corrective-action plan prepared with the manufacturer within 72 hours. Where a Safety Business Gateway filing is required, we support it within four business days. These are Grüner Baum operational service commitments, not statutory reporting deadlines: the applicable legal duty and deadline are assessed separately for the specific incident, economic operator and product.

### How much does an EU Responsible Person cost?

Grüner Baum GmbH charges 249 EUR per year plus VAT for one accepted product family with unlimited SKUs, and 79 EUR per year for each additional family. There is no setup fee. Incident support, such as a recall or a Safety Gate case, is quoted separately. The fee buys a service mandate, not a certificate.

### Which countries does GPSR apply to?

The Regulation governs products placed on the market of the European Union. Sellers established anywhere outside the EU are affected whenever their consumer products reach EU buyers, through a marketplace, a distributor or direct shipping. The seller's own country grants no exemption; what matters is where the product is placed on the market.

### What products are exempt from GPSR?

Article 2 of Regulation (EU) 2023/988 excludes defined categories, among them medicinal products, food and feed, living plants and animals, and certain other listed sectors. Where separate EU legislation already governs a product's safety, that legislation takes precedence and the GPSR applies only to the aspects it does not cover. Exclusion has to be checked against Article 2 product by product.

### Is GPSR required in the UK?

Regulation (EU) 2023/988 governs the EU market, while Great Britain keeps its own product safety rules. A business established only in Great Britain that places products on the EU market still needs an EU-established economic operator under Article 16. Northern Ireland follows separate arrangements, so the correct route should be confirmed per product and per destination market.

### Is the UK's General Product Safety Regulations 2005 the same as the EU GPSR?

No — these are two different instruments that share an acronym. The General Product Safety Regulations 2005 (SI 2005/1803) are United Kingdom law and implemented the earlier EU General Product Safety Directive 2001/95/EC; they continue to apply in Great Britain. The EU GPSR is Regulation (EU) 2023/988, which replaced Directive 2001/95/EC and has applied across the EU since 13 December 2024. Only the EU Regulation creates the Article 16 duty to have an EU-established responsible economic operator. Northern Ireland follows separate arrangements, so the applicable rules should be confirmed per product and per destination market.

### Where can I read the official GPSR text?

The binding text is Regulation (EU) 2023/988, published in the Official Journal of the European Union and available in every EU language on EUR-Lex, where it can also be downloaded as a PDF. The Responsible Person duties are in Article 16, and the four possible economic-operator routes are in Article 4 of Regulation (EU) 2019/1020. The European Commission's notice C/2025/6233 explains how the framework is to be applied in practice. Where a summary and the Regulation disagree, the Official Journal version governs. All three sources are linked at the bottom of this page.

## Canonical page

[Read the complete responsible person page](https://eugpsr.de/en/responsible-person)

## Primary sources

- [Regulation (EU) 2023/988 — EUR-Lex](https://eur-lex.europa.eu/eli/reg/2023/988/oj)
- [European Commission business guidance C/2025/6233](https://eur-lex.europa.eu/eli/C/2025/6233/oj)