EU Responsible Person vs Authorised Representative: what is the difference and which do you need?

"EU Responsible Person" and "Authorised Representative" are two terms that non-EU sellers encounter constantly when trying to comply with EU product regulations. They sound similar, they serve related purposes, and they are easy to confuse — but they are legally distinct roles created by different regulations with different scopes.

Getting this wrong can mean appointing the wrong person, paying for a service you do not need, or — worse — believing you are compliant when you are not.

This guide explains what each role is, where it comes from, when you need one or both, and how they interact.

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The short answer

EU Responsible Person — created by GPSR (Regulation (EU) 2023/988). Applies to essentially all non-food consumer products. Required when a non-EU manufacturer places products on the EU market without an EU-based importer. The EU RP is the named contact for market-surveillance authorities and must appear on the product, packaging, and listing.

Authorised Representative — created by various sector-specific EU directives and regulations (Toys, Machinery, Medical Devices, EMC, Radio Equipment, Low Voltage, PPE, and others). Required when a specific product category has a directive or regulation that mandates CE marking and designates a role for an authorised representative. Also used under PPWR for packaging EPR obligations and under Regulation 2019/1020 for market surveillance.

The key difference: the EU Responsible Person under GPSR is a general, cross-category requirement. An Authorised Representative is a category-specific or regulation-specific requirement. Some products need both. Some need only one. Some need neither (if the manufacturer is EU-based).

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EU Responsible Person — the details

Legal basis

GPSR — Regulation (EU) 2023/988, Article 16. Also Regulation (EU) 2019/1020, Article 4.

When it is required

When all of the following are true:

1. You place a covered consumer product on the EU market.
2. You are not an EU-established manufacturer.
3. There is no EU-established importer carrying the role.
4. There is no EU-established authorised representative already fulfilling the function.

In practice: any non-EU brand selling direct-to-consumer into the EU — through their own storefront, Amazon, Shopify, Etsy, or any marketplace — typically needs an EU Responsible Person.

What they do

• Verify the EU Declaration of Conformity exists (where applicable)
• Hold the technical documentation
• Provide information to authorities on request, in the required EU language
• Cooperate with corrective actions (recalls, withdrawals, Safety Gate notifications)
• Appear as the named contact on the product, packaging, and listing (Article 9 and Article 19)
• Receive consumer complaints about safety

What they do NOT do

• Certify the product
• Issue a CE mark
• Test the product
• Assume the manufacturer's product liability
• Replace an importer

Scope

Applies to essentially all non-food consumer products under GPSR. This is a broad, horizontal requirement — it is not limited to specific product categories.

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Authorised Representative — the details

Legal basis

Various sector-specific directives and regulations:

When it is required

When a sector-specific directive or regulation mandates it — typically when the product requires CE marking and the manufacturer is outside the EU. Not all product categories have this requirement. The obligation comes from the specific regulation governing that product category, not from GPSR.

What they do

The duties vary by regulation, but typically:

• Act on behalf of the manufacturer for specific regulatory obligations
• Hold the technical file and Declaration of Conformity
• Respond to authority requests
• Cooperate with corrective actions
• May carry specific duties defined by the relevant directive (e.g. under the Medical Devices Regulation, the AR has extensive obligations)

Key difference from EU RP

The Authorised Representative is appointed under a specific regulation for a specific product category. The EU Responsible Person under GPSR is a general requirement for consumer products regardless of category. They serve overlapping but distinct legal functions.

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When you need one, the other, or both

Can the same entity serve both roles?

Yes — the same EU-based entity can be appointed as both the EU Responsible Person under GPSR and the Authorised Representative under a sector-specific directive. Many compliance service providers offer combined appointments. However, the mandates are separate documents, and the duties under each regulation are distinct. Make sure both mandates are in place, not just one.

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Common mistakes

Assuming an Authorised Representative covers GPSR. If you sell a CE-marked electronic product and have an Authorised Representative under the Radio Equipment Directive, that appointment does not automatically satisfy the GPSR EU Responsible Person requirement. You need a separate GPSR mandate — or you need the same entity to hold both mandates explicitly.

Assuming an EU Responsible Person covers sector-specific obligations. The reverse is also true. Appointing an EU RP under GPSR does not mean your CE marking obligations are covered. If your product requires an Authorised Representative under a sector directive, you need that appointment separately.

Confusing the Cosmetics Responsible Person. The Cosmetics Regulation (EC 1223/2009) has its own "Responsible Person" — but this is a different legal role with different duties than the GPSR EU Responsible Person. If you sell cosmetics, you need the Cosmetics RP under the cosmetics regulation. Whether you also need a GPSR EU RP depends on whether GPSR applies to your product in addition to the cosmetics regulation.

Using the terms interchangeably. In conversation and in many blog posts, "EU Responsible Person" and "Authorised Representative" are used as if they mean the same thing. They do not. When appointing a service provider, be specific about which mandate you need — GPSR Article 16, or the specific sector directive.

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How to check what you need

The Regonance product scanner identifies which EU regulations apply to your product and flags whether an EU Responsible Person, an Authorised Representative, or both are required — based on the product category, the manufacturer's location, and the applicable regulatory framework.

Check your product now → free, no account

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Compliance guidance based on published EU regulatory texts. Does not constitute legal advice.