GPSR in plain language

First: this is a different law from the packaging one

Most of this site is about packaging — the box, and who pays to recycle it. The GPSR is about the thing inside the box, and it is a separate regulation with a separate timetable, separate authorities and separate penalties. They get merged constantly, usually by people selling a service that covers one of them.

The rule, in one sentence

Article 16(1) is the whole thing, and it is worth reading slowly, because it is written as a prohibition on the product rather than as a duty on you:

So there is no offence of "failing to appoint". There is simply a product that may not lawfully be on the market. That is why the practical consequence turned out to be delisting rather than fines: a marketplace does not have to wait for an authority, it can read the rule itself and take the listing down.

And this is where the confusion about who needs one starts. The Regulation does not say "non-EU sellers must appoint a representative". It says there must be such an operator. If you are established in the EU and you make the product, that operator is already you, and you need to appoint nobody.

Do you need one? Four candidates, in order

Article 4(2) of Regulation (EU) 2019/1020 lists who can be that operator. It is an ordered list, and you stop at the first one that exists.

(a) A manufacturer established in the Union

If you make the product, or have it made and sell it under your own name or trademark, and you are established in the EU — this is you, and you are finished. No appointment, no fee, no service to buy. Most makers inside the Union who panicked in 2024 were already compliant on this point.

(b) An importer, where the manufacturer is not established in the Union

If a business inside the EU brings your goods in and puts them on the market, that importer is the responsible person. A distributor buying from you and reselling in the EU may well be it.

(c) An authorised representative with a written mandate

This is the one you buy. It exists for the case where you are outside the EU and there is no importer — which is exactly the position of a UK, US, Swiss or Norwegian seller shipping direct to EU consumers.

(d) A fulfilment service provider established in the Union

Only "where no other economic operator as mentioned in points (a), (b) and (c) is established in the Union". It is a backstop, not a service you can assume. Warehousing, packaging, addressing and dispatching without owning the goods — plain postal and parcel delivery is expressly excluded.

What the responsible person actually does

Not a mailbox and not a formality — although, unlike the packaging representative, the job is genuinely light once the paperwork exists. Four tasks come from Art. 4(3) of Regulation (EU) 2019/1020, and the GPSR adds two checks of its own in Art. 16(2).

Hold and verify the documentation

Verify that the technical documentation has been drawn up, keep it at the authorities' disposal, and be able to produce it on request.

Answer a reasoned request

Give a market surveillance authority all information and documentation needed to demonstrate conformity, in a language that authority easily understands — which is a practical constraint on who you can appoint.

Report a risk

If they have reason to believe the product presents a risk, tell the authorities.

Cooperate on corrective action

Including making sure immediate corrective action is taken — a withdrawal or a recall — or, failing that, that the risk is mitigated.

Art. 16(2) — check the product against the file

Regularly check that the product still complies with the technical documentation and with the identification and contact-details requirements, and provide documented evidence of those checks on request. The word "documented" is doing work: the checks have to leave a trail.

Art. 16(3) — be findable

Their name and contact details, postal and electronic, go on the product, or on its packaging, the parcel, or an accompanying document. You have four places to choose from; a parcel insert is enough.

What you owe whether or not you need a representative

This is the part that gets lost while everyone argues about representatives. The manufacturer duties in Article 9 apply to you if you make the product or sell it under your own name — including if you are inside the EU and need no representative at all. There is no small-business exemption anywhere in the GPSR.

An internal risk analysis and technical documentation

Before placing the product on the market. At minimum a general description of the product and its essential characteristics relevant to assessing its safety. Where relevant, an analysis of the risks and the solutions adopted, plus any standards applied. Keep it for 10 years. Art. 9(2), 9(3)

A way to identify the product

A type, batch or serial number, or another identifying element — easily visible and legible for consumers, or on the packaging or an accompanying document if the product is too small. Art. 9(5)

Your name and address on it

Name or registered trade name or trade mark, postal and electronic address. On the product, or where that is not possible on the packaging or an accompanying document. Art. 9(6)

Instructions and safety information

In a language easily understood by consumers, as determined by the member state where the product is made available. Not required where the product can be used safely as intended without them — which covers a plain candle-holder and does not cover a candle. Art. 9(7)

A complaints channel

A publicly available telephone number, email address or dedicated section of your website, taking accessibility into account, so consumers can report accidents and safety issues. Art. 9(11)

Accident reporting

Through the Safety Business Gateway, without undue delay, where a product caused death or serious health effects. Art. 20

What has to be in the listing

Article 19 is why your product pages changed, and it applies to you directly — the platform's own duty under Art. 22(9) is only to build fields for it. An online offer must clearly and visibly show at least:

The manufacturer's identity

Name, registered trade name or trade mark, plus a postal and an electronic address at which they can be contacted.

The responsible person, where the manufacturer is not EU-established

Name, postal and electronic address.

Enough to identify the product

Including a picture of it, its type, and any other product identifier. The picture is in the Regulation.

Warnings and safety information

Anything that has to be affixed to the product or its packaging, in a language easily understood by consumers in the member state where it is made available.

What is outside it

Two exclusions matter for the people who read this site, and both are narrower than the hopeful version circulating in seller groups.

Used goods are inside it. Art. 2(3) says the Regulation applies to products "whether new, used, repaired or reconditioned". The only carve-out is for products sold to be repaired or reconditioned before use, and clearly marked as such. "Vintage" is not a legal category — a 1970s dress is a used product unless it clears the antiques test, and most of what is sold as vintage does not.

The GPSR is also a safety net. Where other Union law already regulates the safety of your product — toys, electrical equipment, cosmetics, personal protective equipment — that law governs those risks and the GPSR fills the gaps (Art. 2(1)). If you make toys, the Toy Safety Directive is your problem and it is a much bigger one than this page.

What it costs to get wrong

Here the GPSR is unlike the packaging regime, and the difference is worth knowing before you go looking for a number to be frightened of. Article 44 requires member states to lay down penalties that are "effective, proportionate and dissuasive" and to have notified them by 13 December 2024. It sets no figures at all. Anyone quoting you a pan-European GPSR fine is quoting something that does not exist; the amount is national, and you have to look it up per country.

In practice, the consequence that has actually reached small sellers is not a fine. It is Art. 22: a market surveillance authority can order a marketplace to remove a listing, disable access to it, or display a warning, and the platform has two working days to act. Platforms, facing that, chose to enforce upstream — which is why almost everyone reading this met the GPSR as an onboarding form rather than as a letter from an authority.

Sources

Read directly in the Regulation for this page, not taken from a summary. The GPSR is short and unusually readable, and the articles that decide your position are 2, 3, 9, 16 and 19 — an afternoon, and worth it.

1. Regulation (EU) 2023/988 on general product safety — EUR-Lex Source for the 13 December 2024 application date, Art. 2 (scope and exclusions, including antiques and used goods), Art. 3(8) and 3(20) (manufacturer, antiques), Art. 9 (manufacturer obligations, the 10-year retention, identification, addresses, instructions, complaints channel), Art. 13 (deemed manufacturer, substantial modification), Art. 16 (the responsible person), Art. 19 (distance-selling listing information), Art. 20 (accident notification), Art. 22 (marketplaces, the two-working-day removal order) and Art. 44 (penalties — national, no figures). Read directly for this page
2. Regulation (EU) 2019/1020 on market surveillance — EUR-Lex Source for Art. 4(2) (the ordered list of who can be the responsible person) and Art. 4(3) (the four tasks). Read directly for this page
3. European Commission — Safety Gate and the Safety Business Gateway The portal referred to in Art. 9(8), Art. 20 and Art. 22, and where accident notifications are made

Help us finish this page

This page states the law. What it does not yet have is the thing people actually ask for: what an EU responsible person costs, and whether the cheap ones are real. Nobody publishes a price, the quotes we have seen privately vary by more than a factor of ten, and a service that will not say in writing that it accepts the Art. 16(2) checking duty is not selling you a responsible person. If you have a quote — good or bad — bring it. Anonymised numbers go into the Observatory.