GPSR and the Responsible Person, explained
Who can act as the EU Responsible Person for consumer products under GPSR, what the role holds under Regulation (EU) 2019/1020, and where it stops.
Under the General Product Safety Regulation (GPSR), a consumer product may only be offered for sale in the EU on one condition. An economic operator established in the Union has to be responsible for it. That operator, the Responsible Person, can be an EU manufacturer, an importer, an authorised representative or a fulfilment service provider. Its name and postal address must appear on the product, and on the online listing when the manufacturer is outside the EU.
Suppose a consumer goods brand sells into Europe through online marketplaces. The details are hypothetical, for the mechanics only. It gets a notice from the marketplace. Each listing needs the name and postal address of a responsible person established in the EU, or the listings come down. The products are tested, labelled and selling; the paperwork exists. What the brand does not have is anyone inside the EU legally answerable for its products.
Where the marketplace notice comes from
The notice traces back to the General Product Safety Regulation, Regulation (EU) 2023/988, known as GPSR, which has applied since 13 December 2024. It covers consumer products: goods intended for consumers, or likely to end up in their hands. Article 16 sets the rule for placing such a product on the EU market. It may only be placed there if an economic operator established in the Union is responsible for it. Placed on the market here means offered for sale there.
“Economic operator” is the regulation’s term for a business in the product’s chain, and four kinds qualify for this role. The first is the manufacturer itself if it is established in the EU; the second is an importer. The third is an authorised representative (a company holding a written mandate from the manufacturer). The fourth is a fulfilment service provider, the business that physically stores, packs and ships the goods from inside the Union.
Whichever one it is, that operator is the Responsible Person. Its name and postal address must appear on the product or its packaging. Article 19 extends the duty to distance sales. When the manufacturer sits outside the EU, the online offer itself must show the Responsible Person’s name and address. That is why the enforcement email comes from a marketplace rather than a ministry. Platforms check whether the field is filled in, and suppress listings where it is not.
What the Responsible Person holds
The tasks are set out in Article 4(3) of Regulation (EU) 2019/1020, the EU’s market surveillance regulation, which GPSR points to. In plain language, the Responsible Person:
- verifies that the product’s technical documentation exists (the file of test reports, risk assessments and instructions behind the product) and keeps it available;
- hands that file to a market surveillance authority, the national body that polices product safety, when one asks for it;
- informs the authorities if it has reason to believe a product presents a risk;
- cooperates on corrective action, from a labelling fix to a recall.
It is a documentation, traceability and contact role. The Responsible Person is the fixed EU address a regulator can write to about a product. It is also the party expected to answer with the actual file, batch by batch, rather than with a forwarding address.
How this runs at EFC
EFC takes this role for consumer products only, and only for goods it fulfils from its own operating base in Europe. That base is one operation EFC runs together with Warelog. EFC sits in the regulation’s fourth category, the fulfilment service provider. The address printed on the packaging is therefore the address where the stock physically sits.
When an authority letter arrives, the desk that answers it is the same desk that receives the stock. That desk also holds the documentation file and sees the returns. The questions authorities ask (which batch, which label version, how many units are still in the warehouse) are answered from the warehouse records. They are not relayed to a third party that has never handled the product.
Taking a brand on starts with a documentation review as part of EFC’s compliance work. If the technical file is incomplete, EFC says so before its name goes on the packaging. From then on, EFC is the party answering for it.
Where the role stops
It is consumer products only. Medical devices sit under their own regime with a separate representative structure, and EFC does not act as a medical device authorised representative. If your product is a device, this role is not the answer for it. Fulfilment for device makers is a separate conversation with its own rules.
It is not an import role. The importer of record is the party named on the customs declaration who owes the import duty under Article 77 of the Union Customs Code. It is a different function with different liabilities. One company can hold both roles, but nothing in GPSR makes that automatic.
And it does not replace certification or tax. The Responsible Person verifies that your documentation exists. It does not test the product, issue certificates or grant CE marking, the manufacturer’s own declaration that the product meets EU rules. Where VAT is registered and reported is likewise a separate question, handled under OSS and VAT.
If you are facing the same notice
The working detail is on one page. It sets out what the service covers, what EFC asks of a brand before taking it on, and where the boundaries sit. Start at Responsible Person. Distributors raise the same question before a first order, as set out in what European distributors ask before signing.