GPSR responsible person in the EU for non-EU manufacturers

What the GPSR requires from non-EU manufacturers

The General Product Safety Regulation (EU) 2023/988, known as GPSR, replaced the old General Product Safety Directive and applies from 13 December 2024. It covers consumer products that are not regulated by more specific EU safety law — and many requirements also apply to products that are.

Article 16: no EU operator, no sale

Article 16 of the GPSR says that a product may only be placed on the EU market if there is an economic operator established in the EU responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020 on market surveillance. This operator can be:

• a manufacturer established in the EU;
• an importer, that is the EU company that brings the product from outside the EU;
• an authorised representative appointed by the manufacturer with a written mandate;
• a fulfilment service provider, where no other operator is in the EU.

If your European buyer imports the goods in its own name, it is the importer and often takes this role. If you sell to many small buyers, through marketplaces or with delivered terms, you need an authorised representative.

What the responsible person must do

The tasks under Article 4(3) of Regulation 2019/1020 are practical: keep the EU declaration of conformity and the technical documentation available to authorities, provide information and documents in a language they understand, cooperate with them, inform them when there is reason to believe a product is dangerous, and help to remove or reduce risks — up to a recall.

This is why a post-box address does not work. Authorities expect a real company with staff who answer letters, can reach the manufacturer and can act quickly.

What must be on the product

GPSR requires product identification (type, batch or serial number), the name, trade name or trade mark and the postal and electronic address of the manufacturer, and the name and contact details of the EU responsible person. This information must be on the product, its packaging, the parcel or an accompanying document. Warnings and safety information must be in the language of the country where the product is sold.

Online offers must show the same: manufacturer, EU operator, product identification and warnings. This is why Amazon, Allegro, Kaufland and other marketplaces now ask for the responsible person when you list.

How we take the role

We are EnjoyGroup Sp. z o.o., a company registered in Poland. Before we sign a mandate we check your documents for each product range: test reports, declarations, labels, instructions and risk information. Then we sign a written mandate that defines the products, our tasks, how you send us documents and how we act together in case of an incident.

We do not take the role for products whose documents we have not reviewed, and we do not certify your products. The safety of the product and the conformity assessment remain the manufacturer’s responsibility.