GPSR EU Responsible Person: What Non-EU Brands Must Show, and How to Check It

Selling into the EU from outside it has one extra requirement under the General Product Safety Regulation (GPSR): every product needs an economic operator established in the EU who is responsible for it, and every online offer must say who that is. This applies to brands in the UK since Brexit, in the US, Switzerland, China and everywhere else outside the EU.

It is one of the four things every EU product page has to show, alongside the manufacturer, a product identifier and the warnings. Our GPSR checklist covers all four; this post is about the EU contact. EcoClaim's free GPSR check flags listings where the manufacturer is outside the EU and no EU contact is shown.

Who can be the EU responsible person

Article 16 of the GPSR refers to Article 4 of the Market Surveillance Regulation (EU) 2019/1020. Under it, the role falls to one of these, in this order:

1. A manufacturer established in the EU. Then no separate EU contact is needed.
2. An importer established in the EU, that is, the business that places the product from outside the EU on the EU market.
3. An authorised representative established in the EU, appointed by the manufacturer with a written mandate to carry out these tasks.
4. A fulfilment service provider established in the EU, for the products it handles, where none of the above exists.

Many non-EU brands that sell directly to EU consumers have no importer of their own, because the customer is legally the importer. They usually appoint an authorised representative, a service several compliance providers offer.

What the role involves

The EU responsible person is the contact for market surveillance authorities. It keeps the product's documentation available, cooperates with the authorities, informs them when a product presents a risk, and takes part in corrective action such as a recall. It is a real legal role, not just an address on a page: choose a provider that will actually answer.

What to show on the product page

Article 19(b) asks for the same three details as for the manufacturer: name, postal address and electronic address. Put them directly below the manufacturer's details, with a clear label, in every product description or product details section:

Manufacturer: [Company name], [Street No.], [City], [Country outside the EU], [email]. EU responsible person: [Company name], [Street No.], [Postcode City], [EU country], [email]

Labels vary in practice ('EU responsible person', 'EU representative', 'Importer'). What matters is that a shopper can see who the EU contact is and how to reach them. As with the manufacturer, an email address or a direct contact form counts as electronic address; a homepage alone does not.

Common mistakes

• The EU contact is only in the shop's legal notice. It must be on each offer.
• The EU contact has no email or contact form, only a postal address.
• The manufacturer's address is missing, so nobody can tell whether it is in the EU. Show both.
• A UK address treated as EU. Since 2021, the UK is outside the EU for this purpose.
• One brand in the catalogue is forgotten, typically a newer supplier added after the clean-up.

Free GPSR checker: scan and fix every product page

That last one is why checking every page matters. In an EcoClaim scan, each product page shows whether the manufacturer is in the EU and, if not, whether an EU contact is shown. When the page does not reveal where the manufacturer is, the result is 'Couldn't confirm', never a breach. The safety check is free in every scan from an EcoClaim account, and re-checking after a fix is free.