GPSR responsible person: EU requirements for non-EU sellers, explained

November 3, 2026 · by Lucas Reda · in Cash on Delivery · 20 min read

The GPSR requires an EU-based economic operator for almost every non-food consumer product. Who can fill the role, what goes on the GPSR label and the listing, and how cosmetics and supplements differ.

A GPSR responsible person is the economic operator established in the EU that answers for a product under Regulation (EU) 2023/988, applicable since December 13, 2024. It must be an EU manufacturer, an importer, an authorised representative with a written mandate or, as a last resort, a fulfilment service provider. Its name and contact details go on the product and in the listing.

Updated on October 8, 2026.

Most non-EU sellers meet the GPSR the hard way. A marketplace blocks the listing, a supplier asks "who is your EU responsible person?", or a shipment reaches a European warehouse with a label that names nobody in Europe. Search for "GPSR responsible person" and the first page is mostly companies selling that exact service. This guide takes a different route: it starts from the official text, lays out the four ways to comply, and makes clear which decisions are yours.

This article summarises public EU rules. It is not legal or regulatory advice and does not assess any product. Validate classification, labelling and your choice of operator with a regulatory specialist before you sell.

What is the GPSR and when did it start applying?

The GPSR is Regulation (EU) 2023/988 on general product safety, and it has applied since December 13, 2024 (Article 52). It replaced the 2001 General Product Safety Directive and is directly binding in every Member State, with no national transposition needed.

The core rule is short: only safe products may be placed or made available on the market (Article 5). What changed in practice is the chain of responsibility. The regulation now requires someone inside the EU to answer for each product, expands what an online listing must show, and adds specific duties for online marketplaces and for recalls.

Three scope points clear up most of the confusion:

• It covers non-food consumer products. Apparel, accessories, kitchenware, simple electronics, toys, home decor, non-cosmetic beauty tools, gadgets. Article 2(2) expressly excludes medicinal products, food, feed, live plants and animals, plant protection products and antiques, among others.
• It is a safety net. Where specific EU law already regulates a product's safety, the GPSR only covers the aspects and risks that law does not cover (Article 2(1)). Toys, electrical equipment and cosmetics keep their own rules.
• It reaches online sales from outside the EU. Under Article 4, a product offered at a distance is made available on the EU market if the offer targets consumers in one or more Member States. A page in Polish, prices in euro and delivery to Italy are clear signs of targeting.

Products placed on the market before December 13, 2024 that complied with the old directive may still be sold (Article 51). That does not help a new seller: any new batch follows the new rules.

Who needs an EU responsible person?

You need one if you place a GPSR-covered product on the EU market and no economic operator established in the EU is responsible for it. Article 16(1) is blunt: a product cannot be placed on the market unless an economic operator established in the Union is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020, the Market Surveillance Regulation.

The typical case is the non-EU seller selling directly to EU consumers: a Shopify store, an affiliate offer, a marketplace account. If you are the manufacturer (the product carries your brand, and under Article 13 anyone who places a product on the market under their own name or trademark is treated as the manufacturer) and you have no EU company, the piece the law requires is missing.

If you own a company established in an EU country and that company places the product on the market under its brand, it is an EU manufacturer and fills the role. If a European distributor buys your batch and imports it in its own name, it is the importer. The gap appears when nobody in Europe takes on anything.

This is the core of "GPSR responsible person for non-EU sellers": the obligation sits with the product, not with where your company is registered. The Commission guidelines for businesses, published in the Official Journal on November 21, 2025, state that for products covered by the GPSR you may only place a product on the EU market if there is a responsible person for it established in the EU.

What are the 4 types of economic operator that can be the responsible person?

There are four, and the order matters. Under Article 4(2) of Regulation 2019/1020, applied to the GPSR by Article 16, the responsible person is one of: a manufacturer established in the EU; an importer, where the manufacturer is not in the EU; an authorised representative with a written mandate from the manufacturer; or a fulfilment service provider established in the EU, for the products it handles, where none of the first three exists.

Points the service-provider pages tend to skip:

• Distributors are not on the list. A distributor is an economic operator with its own duties (Article 12), but it is not one of the four that can be the responsible person under Article 4(2).
• The mandate must be written. An authorised representative only exists with a written mandate from the manufacturer designating it for the Article 4(3) tasks. An informal agreement does not count.
• The name goes on the product. Whoever it is, its name, registered trade name or trademark and contact details, including postal and electronic address, must appear on the product, its packaging, the parcel or an accompanying document (Article 16(3)).

The choice between these routes is yours, not the warehouse's, the marketplace's or the COD platform's. It depends on your product, volume, countries and how much control you want. Discuss it with a regulatory specialist before signing anything.

What does the responsible person actually do?

A responsible person is not just a name to print on a label. It has legal tasks and answers to market surveillance authorities. Under Article 4(3) of Regulation 2019/1020 combined with Article 16(2) of the GPSR, it must:

1. verify that technical documentation has been drawn up and ensure it can be provided to authorities on request;
2. answer a reasoned request from an authority with all necessary information, in a language that authority understands;
3. inform authorities when it has reason to believe the product presents a risk;
4. cooperate so that corrective action is taken, including withdrawal or recall;
5. regularly check, where the risk warrants it, that the product matches its technical documentation and carries identification, manufacturer details and instructions in the right language, keeping evidence of those checks;
6. ensure serious accidents are notified through the Safety Business Gateway when the manufacturer is outside the EU (Article 20(4)).

That is why a serious representative asks for your technical documentation before accepting a product, and may say no. If your supplier sends nothing but photos and a price, the problem is not the representative. The product has no documentation.

Does storing stock with an EU fulfilment provider make it your economic operator?

Not by itself, and relying on it is risky. The fulfilment service provider only appears as responsible person in Article 4(2)(d) of Regulation 2019/1020, and only where no EU manufacturer, importer or authorised representative exists. It is a last-resort rule, written so that authorities always have someone in Europe to turn to. It is not a service bundled with storage.

The Commission guidelines say a fulfilment service provider is always an economic operator (it needs internal safety processes and must cooperate with authorities) and warn that it can end up as the responsible person when nobody else is there. That is exactly why logistics providers set out in their contracts what they will and will not take on. The law also asks for more than physical custody: the responsible person's name must be on the label, it needs access to the technical documentation and it must be able to run the checks. A provider that has not accepted the role will not print its name on your packaging.

Four practical consequences:

• Read the contract. It says whether the fulfilment provider accepts being the responsible person. If it is silent, assume it does not.
• Appoint your operator before shipping. Labels are printed before the shipment leaves. Finding out in Europe that a name is missing means relabelling the whole batch.
• At N1, the answer is no. N1 runs inventory in our warehouses in Europe and cash on delivery, but it is not the GPSR economic operator for sellers' products and does not act as responsible person. Sellers need their own EU operator. More on how our warehouse network and Europe structure work.
• The legal order works in your favour. Once you appoint an authorised representative or have an importer, fulfilment goes back to being just fulfilment.

GPSR requirements: what must appear on the listing, the label and the packaging?

The online listing must show four pieces of information (Article 19), and the physical product must carry identification, manufacturer details, responsible person details and instructions in the local language (Articles 9, 11 and 16). Use the list below as a checklist.

On the product page or listing (Article 19)

• Name, registered trade name or trademark of the manufacturer, with postal and electronic contact address.
• Where the manufacturer is not in the EU: name, postal and electronic address of the responsible person.
• Information identifying the product: a picture, its type and any other product identifier (model, reference, batch where relevant).
• Any warning or safety information that goes on the product or packaging, in a language consumers in that country easily understand, as determined by that Member State.

The text requires this information to be shown clearly and visibly in the offer. Burying it in a terms page footer does not meet it. According to the Commission guidelines, an "electronic address" can be an email address or a website section that allows direct contact. A website alone is not enough.

The GPSR label: on the product, packaging or an accompanying document

• Type, batch, serial number or other identifier, visible and legible (Article 9(5)). If size does not allow it, on the packaging or an accompanying document.
• Manufacturer's name, trademark, postal and electronic address (Article 9(6)).
• Importer's name and contact details, if there is one (Article 11(3)), without hiding the manufacturer's information.
• Responsible person's name and contact details (Article 16(3)), on the product, packaging, parcel or an accompanying document.
• Clear instructions and safety information in the language set by the country where the product is sold (Article 9(7)), unless the product can be used safely without them.

Article 21 allows this information to also be offered digitally, such as through a QR code, as a complement, not a replacement for what must be on the product. For multi-country sellers, language is the costly part: a batch for Poland, Hungary and the Czech Republic needs three instruction versions or a multilingual leaflet.

Internal risk analysis and technical documentation: what do you need?

Before placing a product on the market, the manufacturer must carry out an internal risk analysis and draw up technical documentation with at least a general description of the product and the characteristics relevant to assessing its safety (Article 9(2)). Where the risk justifies it, the file includes an analysis of possible risks, the solutions adopted, test reports and the list of European standards applied.

The size of the file follows the product's risk. A tea towel needs little. A battery-powered hand warmer needs much more and probably falls under specific electrical legislation too. Documentation must be kept up to date and retained for 10 years after the product is placed on the market (Article 9(3)).

What trips up sellers buying from Asian suppliers is that, for the GPSR, you are the manufacturer when the product carries your brand. The technical documentation becomes your obligation, and the supplier becomes your data source: composition, materials, tests, safety data sheets. Ask for it when you negotiate the batch, not after shipping.

Add a simple internal process: Article 14 requires internal product safety processes, and Article 9(12) asks for a register of complaints, recalls and corrective measures. In a cash on delivery operation, customer service already receives these complaints. Log the ones about safety.

What changes between selling on a marketplace and on your own store?

Your obligations as a seller are the same on both channels: the listing needs the Article 19 information and the product needs an EU responsible person. The difference is who checks first. On a marketplace, the platform has its own duties and will ask you for the data. On your own store, nobody asks before the authorities do.

Under Article 22, online marketplaces must have a single point of contact for authorities and consumers, register on the Safety Gate portal, act on orders to remove dangerous offers within two working days and process safety notices within three working days. Paragraph 9 requires the marketplace interface to let traders provide manufacturer, responsible person, identification and warnings for each product, and to display them on the listing. Paragraph 11 requires suspending, after a warning, traders that frequently offer non-compliant products. Per the Commission guidelines, some of these duties apply only to medium and large marketplaces, which are exactly the ones you will sell on.

On your own store (Shopify, a landing page for an affiliate offer), there is no intermediary filtering anything. Enforcement arrives through a consumer complaint, an online sweep by authorities or an accident. The product page needs the same care, and you do not share the responsibility with anyone.

GPSR responsible person vs. cosmetics responsible person: what is the difference?

They come from different laws. The cosmetics responsible person comes from Article 4 of Regulation (EC) No 1223/2009 and exists only for cosmetic products. The GPSR one applies to other non-food consumer products. A seller offering a serum and a hairbrush may need both.

Before a cosmetic is placed on the market, the responsible person submits an electronic notification through the Commission's Cosmetic Products Notification Portal (CPNP) (Article 13). For cosmetics, the specific safety rules are those of Regulation 1223/2009. The GPSR only fills what that regulation does not cover.

Are food supplements covered by the GPSR?

As a rule, no. Food supplements are food under Directive 2002/46/EC, and Article 2(2)(b) of the GPSR excludes food. Supplement safety and labelling follow food law: national notification, labelling in the local language and authorised health claims only.

Under food law, the operator responsible for consumer information is the one under whose name the product is marketed or, if that operator is not in the EU, the importer (Article 8 of Regulation 1169/2011). So supplements also need someone in Europe, under a different law. Check national procedures with each authority before you sell.

Watch what ships with it. A shaker bottle, a measuring tape or a device bundled in the kit is not food. That item may fall under the GPSR or specific legislation and needs its own assessment.

What happens with accidents and recalls?

When a product causes a serious accident, the manufacturer must notify the authority of the country where it occurred, without undue delay, through the Safety Business Gateway, the Commission's portal for businesses (Article 20). If the manufacturer is outside the EU, the responsible person ensures the notification is made.

An accident here means an occurrence that resulted in death or serious adverse effects on health and safety, including injuries and illnesses (Article 20(2)). Identifying a dangerous product also triggers action: corrective measures, withdrawal or recall, informing consumers and notifying authorities through the same portal (Article 9(8)).

A recall has a defined format:

• affected consumers who can be identified are notified directly (Article 35);
• a written notice follows a fixed template: the headline "Product safety recall", a picture, batch number, a description of the hazard that does not downplay it, what to do and the remedy offered (Article 36);
• consumers choose between at least two remedies among repair, replacement or a refund of at least the price paid, and never pay return shipping (Article 37).

Cash on delivery has an underrated advantage here: every COD order already holds the customer's name, phone number and address. Article 35 requires you to use the data you already collect to notify them. Keep that base organised and compliant with data protection rules.

What are the GPSR penalties?

The GPSR sets no fine amounts. Article 44 requires each Member State to lay down penalties that are effective, proportionate and dissuasive, and to notify those rules to the Commission. Amounts and procedures vary by country.

In operations, what hits before any fine is listing removal, a withdrawal order, a marketplace suspension and stock stuck in a warehouse that cannot be sold. If you need the fine for a specific country, check that country's national law, ideally with a local specialist.

Step by step: a non-EU seller with stock in a European warehouse

Hypothetical example: you sell a kitchen organiser under your own brand, made in China, stocked in a warehouse in Europe, with cash on delivery in Poland, Italy and Hungary. The path, in order:

1. Classify the product. General product (GPSR), cosmetic, food or specific legislation (toys, electrical, food contact materials)? Classification decides who is responsible and which documents apply.
2. Assume you are the manufacturer. If it carries your brand, the law treats you as the manufacturer (Article 13), even if another company makes it.
3. Choose your EU operator. Your own EU company (manufacturer or importer) or an authorised representative with a written mandate. The decision is yours. Do not count on fulfilment.
4. Build the technical documentation. Risk analysis, description, materials, tests and standards applied, with data requested from the supplier before ordering the batch. Keep it for 10 years.
5. Lock the label before production. Product identification, manufacturer, responsible person and instructions in Polish, Italian and Hungarian. Packaging support belongs in the production phase.
6. Fix the product page. The four Article 19 items, visible, in every country version of the store.
7. Formalise roles by contract. The fulfilment contract says what the provider does; the representative's mandate says what it assumes. One does not replace the other.
8. Prepare an incident plan. Who receives safety complaints, who logs them, who notifies via the Safety Business Gateway and how you reach customers.
9. Review for every new country or product. Language, classification and national rules change.

If the product is a supplement or a cosmetic, steps 1, 3 and 4 change: national notification or the CPNP and the specific law's responsible person come in. In those cases N1 can help with registration and notification and, when needed, provide an EU responsible party for that purpose, through consulting and production. That is different from the GPSR economic operator role, which N1 does not take on.

What this means if you sell with cash on delivery and local stock

The GPSR weighs more on sellers shipping order by order from China than on those with stock in Europe. With local stock, the batch is prepared once: correct label, documentation gathered and an EU operator appointed before shipping. With direct shipping, each parcel crosses the border without anyone in Europe answering for it.

Local stock also lines up with other recent changes. Low-value parcels from outside the EU now pay the flat duty explained in our post on the EU de minimis removal and the 3 euro duty, and the EU–Mercosur agreement changes tariffs for sellers moving batches into Europe. If you have no product yet, the route to sell in Europe without inventory through affiliation leaves these obligations with the product owner. And if you are still choosing what to sell, the post on best-selling products in Europe helps weigh the regulatory risk of each category.

What N1 does here: stores your inventory in our warehouses in Europe and the Gulf, delivers with cash on delivery (COD) in 16 markets and pays out on D+2. What N1 does not do: act as the GPSR responsible person for your product. Being clear about that from day one avoids stock that cannot move.

Frequently asked questions

What is a GPSR responsible person?

It is the economic operator established in the EU that is responsible for a product under Article 16 of Regulation (EU) 2023/988. It can be an EU manufacturer, an importer, an authorised representative with a written mandate or, as a last resort, a fulfilment service provider.

Do non-EU sellers need a GPSR responsible person?

Yes, if they sell GPSR-covered products to EU consumers and have no EU manufacturer or importer. For sellers with no European company, the most common route is an authorised representative with a written mandate. The choice belongs to the seller.

What are the EU responsible person requirements on the label?

The responsible person's name, registered trade name or trademark and contact details, including postal and electronic address, must appear on the product, its packaging, the parcel or an accompanying document. The manufacturer's details and a product identifier are also required.

What is a GPSR label?

It is the set of information the product must carry: type, batch or serial number, manufacturer details, responsible person details and safety instructions in the local language. A QR code can complement it but not replace it.

Can my fulfilment warehouse be my responsible person?

Only as a last resort and only if it agrees. Under Article 4 of Regulation 2019/1020, fulfilment only comes in when there is no EU manufacturer, importer or authorised representative. N1 does not take on this role.

Do cosmetics and supplements follow the GPSR?

Supplements are food and, as a rule, fall outside the GPSR; they follow food law. Cosmetics have their own regulation, with a responsible person and CPNP notification. The GPSR only covers what those laws do not.

Next step

If you want to move stock into Europe and sell with cash on delivery, N1 handles storage, delivery and payouts, and supports supplement and cosmetic registration and notification when needed. The GPSR economic operator for your product remains your choice. Talk to a specialist or see N1 consulting.