Selling to the EU from the UK? GPSR means you need a Responsible Person

If you are a UK business selling physical products to consumers in the EU, the General Product Safety Regulation (Regulation (EU) 2023/988, GPSR) requires you to have someone inside the EU or EEA who is legally responsible for your product's safety paperwork. Without that person, your product may not lawfully be placed on the EU market — and in practice, marketplaces will stop your listings before any authority contacts you.

This is one of the sharpest post-Brexit consequences for small exporters, and it catches businesses that have been shipping to EU customers for years without incident. Nothing about your product changed. The legal geography did.

Why UK sellers are affected

Before Brexit, a UK company selling into the EU was an EU-established economic operator. The GPSR, applicable since 13 December 2024, requires that every product placed on the EU market has a responsible economic operator established in the Union. A UK company, post-Brexit, is not established in the Union.

So if you sell direct to EU consumers — your own webshop, Amazon EU, Etsy, eBay, a marketplace in Germany or France — you need an EU Responsible Person, unless there is already an EU-established importer or manufacturer in your chain who takes that role.

Note the Northern Ireland nuance: under the Windsor Framework, goods placed on the market in Northern Ireland follow EU product rules, which affects how some UK businesses structure their arrangements. Take advice if that applies to you.

What the Responsible Person actually does

The role, set out in Article 16 GPSR, is a specific set of duties rather than a mailbox. Your Responsible Person must:

• verify that the required Declaration of Conformity (where applicable) and technical documentation have been drawn up;
• keep that documentation available for authorities for ten years;
• provide information and documentation to market surveillance authorities on request, in a language they accept;
• cooperate with authorities on corrective action, including recalls and withdrawals;
• inform authorities where they have reason to believe a product presents a risk.

Two consequences follow. First, this is not a nominee arrangement — the person or company must genuinely hold or be able to obtain your product file. Second, their name and contact details must be visible to consumers: on the product, its packaging, the parcel or an accompanying document, and, for distance selling, in the online offer itself.

Who can be your Responsible Person

Any of the following, provided they are established in the EU or EEA:

• an EU-established manufacturer, if you manufacture through one;
• an importer, meaning the EU business that first brings your product into the Union;
• an authorised representative you appoint by written mandate;
• a fulfilment service provider, where no other operator in the chain qualifies.

For a typical UK brand shipping direct to consumers, there is no EU importer, because the consumer is importing. That is precisely the gap the requirement closes, and it is why an authorised representative is the usual answer.

A word on structures people try. A friend or relative in Ireland is not a solution unless they will genuinely hold documentation and respond to authorities. An EU-registered company shell with no operational presence is the same problem in a suit. A freight forwarder is not automatically your Responsible Person. And listing an address you do not control is a misrepresentation on the face of your own listing.

How to appoint one, step by step

1. Prepare the product file. Product identification and photographs, a description of intended use, applicable standards, test reports, risk assessment, a Declaration of Conformity where sector rules require it, traceability information such as batch or serial numbering, warnings and instructions in the languages of the markets you sell into, and your production or supplier controls. If you cannot assemble this, no Responsible Person can accept the mandate, and the file is what an authority asks for first.

2. Choose a provider. Options are a commercial EU Responsible Person service, an EU-established distributor already buying from you, or your own EU entity if you have one. Compare on documentation handling, languages covered, per-product versus per-portfolio pricing, and how they handle authority requests and incident reporting — not on price alone.

3. Sign a written mandate. It should name the products covered, list the Article 16 tasks, set information-flow and response obligations in both directions, cover document retention for ten years, and state termination and handover terms. Vague mandates fail when they are actually needed.

4. Publish the details. Name and postal address, plus an electronic contact point, must appear in your online offer and on or with the product. On marketplaces, complete the safety and compliance fields rather than burying the information in a description block.

5. Keep it alive. Update the file when you change suppliers, materials or product specification. Reconfirm the mandate covers new SKUs. A mandate that covers last year's catalogue is not a defence for this year's product.

What happens without one

The escalation is predictable. Marketplaces enforce first, because the GPSR obliges them to collect and display this information: the compliance field is unfilled, the listing is suppressed, and your sales in that market stop overnight. Customs and market surveillance can refuse or detain goods. Authorities can order withdrawal or recall. National penalties apply on top.

The commercial damage nearly always arrives through the listing suppression, weeks before anything legal happens. That is why treating this as a paperwork chore with a distant deadline reads the risk wrongly.

The related requirements people miss

Getting an EU Responsible Person does not complete your EU compliance picture. The same UK business selling packaged goods also needs national EPR registration for packaging, and under the PPWR may need separate authorised representation for packaging. Any environmental claim in your listings sits under the EmpCo rules. Products in regulated categories still need CE marking and the correct conformity route, with the Responsible Person holding the file rather than replacing the assessment.

What it costs and how long it takes

Commercial EU Responsible Person services are typically priced per product family per year, with a lower rate for portfolios and a higher rate where documentation support is included. The cost driver is rarely the mandate itself: it is the state of your product file. A brand with test reports, a risk assessment and translated instructions ready can be live in days. A brand starting from photographs and a supplier email may need weeks of documentation work first, and reputable providers will not sign a mandate until that work is done, because they inherit the exposure.

Budget for translation separately. Warnings and instructions in six market languages, produced by someone competent in safety language rather than a general translator, is a real line item and a recurring one as your catalogue grows.

Two structures that work for growing UK brands

Appoint a commercial representative per product family. Lowest fixed cost, fastest to arrange, and it scales badly only when your catalogue becomes very broad. Most UK sellers under a few hundred SKUs land here.

Sell through a single EU distributor of record. If one EU-established business buys from you and places goods on the market, it becomes the importer and carries the Article 16 role for those goods. This can simplify your position considerably, but only where the commercial relationship is genuinely wholesale — dropshipping arrangements dressed as wholesale do not move the obligation, because the goods still reach the consumer as your sale.

Setting up your own EU entity is the third option and rarely pays for itself below meaningful EU revenue, since the entity then needs somebody competent to actually perform the duties.

Common questions

Does this apply to sales through Amazon EU? Yes. Selling through a marketplace does not create an EU importer, and the marketplace is obliged to display the responsible operator's details.

What if my EU sales are small? There is no de minimis exemption for the Responsible Person requirement. A single unit shipped to a consumer in the EU is a product placed on the EU market.

Does an EU-based warehouse solve it? A fulfilment service provider can hold the role where no other operator qualifies, but confirm in writing that yours accepts it — most 3PL contracts do not, by default.

Is this the same as my cosmetics or packaging representative? No. The cosmetics Responsible Person, the PPWR authorised representative and the GPSR Responsible Person are distinct appointments, even when one provider covers several.

A short checklist

• Do you sell physical goods to EU consumers? If yes, continue.
• Is there an EU-established manufacturer or importer in your chain? If no, you need to appoint someone.
• Is a Responsible Person named, with a postal address, in every EU listing and on the product? If no, fix this first.
• Is a complete technical file available to them within days, not months?
• Is the mandate written, current, and covering your live SKUs?
• Are your instructions and warnings in the languages of the markets you sell into?
• Are you registered for packaging EPR in each country you ship to?

Educational information only, not legal advice. Sector-specific rules and national penalties vary — confirm your obligations for each market and product category with a qualified advisor.