GPSR and the Responsible Person, explained
The marketplace notice behind GPSR: who can carry the EU Responsible Person role for consumer products, what the role holds, and where it stops.
Picture a consumer goods brand selling into Europe through online marketplaces. It gets the notice most non-EU sellers now get: add the name and postal address of a responsible person established in the EU to each listing, or the listings come down. The products are tested, labelled and moving; the paperwork exists. What the brand does not have is anyone inside the EU legally answerable for its products, and no listing survives that gap for long.
The rule the marketplace was enforcing
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 says such a product may only be placed on the EU market, meaning offered for sale there, if an economic operator established in the Union is responsible for it.
“Economic operator” is the regulation’s term for a business in the product’s chain, and four kinds qualify for this role: the manufacturer itself if it is established in the EU, an importer, an authorised representative (a company holding a written mandate from the manufacturer), or 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, and 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, and 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 specifically for goods it fulfils from its own operating base in Europe, one operation EFC runs together with Warelog. The regulation’s fourth category, the fulfilment service provider, is the seat we occupy, so the address printed on the packaging is the address where the stock physically sits.
That combination is the practical point. When an authority letter arrives, the desk that answers it is the same desk that receives the stock, 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) get answered from the warehouse records, not relayed to a mailbox company that has never touched the product.
Taking a brand on starts with a documentation review as part of our compliance work. If the technical file is incomplete, we say so before our name goes on the packaging, because once it is there, we are the ones answering for it.
Where the role stops
The boundary is worth stating as plainly as the service.
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, the party named on the customs declaration who owes the import duty under Articles 77 and 84 of the Union Customs Code, 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 lives on one page: what the service covers, what we ask of a brand before we take it on, and where the boundaries sit. Start at Responsible Person.