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Folio 02 · GuideGB Dossier

Responsible person and authorised representative: who answers for your product in the EU

Reviewed by Hatice Muazzez Bodur · Managing Director & Co-Founder, Grüner Baum GmbH
Last updated: October 5, 2026 · Published by Grüner Baum GmbH, Oppenheim (Rhenish Hesse), Germany

The responsible person is a business established in the EU that answers to the authorities for a consumer product. Without one, the product may not be placed on the EU market. The role can be held by the manufacturer, the importer, an authorised representative or a fulfilment service provider; for manufacturers outside the EU with no importer, Grüner Baum GmbH of Oppenheim, Germany, takes it on as authorised representative.

This page is not legal advice, and Grüner Baum GmbH is not a law firm. Our guide to the Product Safety Regulation gives an overview of all duties; the exact legal references are listed at the end under Legal basis.

Contents

  1. The rule in a few sentences
  2. The four routes to a responsible person
  3. What the responsible person must do
  4. Decision guide: who is responsible in your supply chain?
  5. When you need an external authorised representative, and when you do not
  6. How Grüner Baum GmbH takes on the role of authorised representative
  7. Frequently asked questions about the responsible person
  8. Legal basis

The rule in a few sentences

For every product covered by the Product Safety Regulation, it must be clear which business in the EU answers to the authorities for certain safety tasks. That business’s name or registered trademark and its contact details, including a postal and an email address, appear on the product, its packaging, the parcel or a document supplied with it.

It is usually called the “responsible person”, which is also the term the Regulation uses for the details in online offers. It is not a profession of its own but a task taken on by one of four possible businesses. Which ones is set out in the EU Market Surveillance Regulation, to which the Product Safety Regulation refers.

The four routes to a responsible person

Route 1: the manufacturer established in the EU

If the manufacturer is established in the EU, it is itself the responsible person. That also applies to own-brand companies that have goods made abroad and sell them under their own name, because they count as manufacturers. No additional appointment is needed.

Route 2: the importer

If the manufacturer is established outside the EU, the importer can hold this role. That is the business in the EU that brings the goods from a non-EU country onto the EU market for the first time. If you are a retailer in Germany buying directly from a manufacturer in Asia or America and importing the goods yourself, that is as a rule you.

Route 3: the authorised representative

A manufacturer outside the EU can mandate a business in the EU in writing to carry out these tasks on its behalf. On request, the authorised representative shows the authorities a copy of the mandate. This route is mainly needed where there is no importer in the EU, for instance because the manufacturer sells to customers in the EU itself through an online shop or a marketplace.

Route 4: the fulfilment service provider

Only if no manufacturer, importer or authorised representative is established in the EU is a fulfilment service provider in the EU responsible, and then for the products it handles. A fulfilment service provider is a business that provides at least two of these services for goods it does not own: warehousing, packaging, addressing, dispatching. Postal, parcel and freight services do not count.

What the responsible person must do

Whichever route applies, the tasks are the same. The responsible person must

  • check that the technical documentation has been drawn up and make sure the authorities receive it on request,
  • give the authorities, on a reasoned request, all information and documents on the product’s safety, in a language they can easily understand,
  • inform the authorities if it has reason to believe that a product presents a risk,
  • cooperate with the authorities and make sure defects are put right without delay,
  • make sure that an accident involving a product of a manufacturer outside the EU is reported.

On top of this come regular checks, to the extent the product’s risks call for them: does the product match its technical documentation? Do the product or its packaging carry the identifier, contact details, instructions and safety information? The responsible person records the results in writing and shows them to the authorities on request. If this evidence is missing, or its contact details are missing from the product, packaging, parcel or insert, a fine is possible in Germany.

Decision guide: who is responsible in your supply chain?

The overview maps typical supply chains. It does not replace a case-by-case review, but it shows where the role usually lies.

Your situationYour roleResponsible person
You manufacture in Germany and sell under your own name.ManufacturerYou (route 1)
You have goods made outside the EU and sell them under your brand.Manufacturer (own brand)You (route 1)
You buy from a manufacturer outside the EU and import the goods yourself.ImporterAs a rule you, as importer (route 2)
You buy from a manufacturer or wholesaler in the EU.DistributorThe manufacturer in the EU or the importer who brought the goods into the EU
Goods are shipped from a non-EU country directly to your customers.Clarify first: distributor or importerYou as importer (route 2) or an authorised representative of the manufacturer (route 3)
You manufacture outside the EU and supply an importer in the EU.ManufacturerAs a rule your importer (route 2)
You manufacture outside the EU and sell to customers in the EU yourself, for example through your own shop or a marketplace.ManufacturerAn authorised representative in the EU that you mandate in writing (route 3)

Look especially closely at direct shipping from a non-EU country. Before the first offer, establish who places the goods on the market in the EU. That decides whether a retailer is the importer itself or whether the manufacturer needs an authorised representative.

When you need an external authorised representative, and when you do not

You do not need an external authorised representative if a business in the EU already holds the role: you yourself as manufacturer or brand owner, you as importer, or the manufacturer or importer you buy from. An additional service provider would not take any of your own duties off your hands.

An authorised representative is needed if the manufacturer is established outside the EU and no importer in the EU places the goods on the market. This is typical for direct sales from a non-EU country through online shops or marketplaces. Without a responsible person the product may not go on the market, and the online offer must show that person’s name, postal address and email address.

For retailers this means: if you sell products of a manufacturer outside the EU online, the responsible person’s details belong in your offer. Ask your supplier who holds this role before your first offer, and get the contact details in writing.

An authorised representative does not take responsibility for product safety away from the manufacturer. It carries out the tasks set out in the written mandate, and that mandate must cover at least the tasks required by law. One business established anywhere in the EU is enough; you do not need a separate one in each EU country. You still check language, warnings and product-specific rules for every target market.

How Grüner Baum GmbH takes on the role of authorised representative

Your contracting party is Grüner Baum GmbH itself, registered with the Mainz Local Court (Amtsgericht Mainz) under HRB 52165, Vorstädter Str. 32, 55276 Oppenheim, Germany. The mandate does not arise from an enquiry or from visiting this website, but in four steps:

  1. Enquiry: you describe which products you want to sell in the EU, where they are made and through which channels you offer them.
  2. Review before acceptance: we look at the product category, the applicable product safety and sector rules, the technical documentation, the labelling and the product’s position in the supply chain. We point out any gaps before anything is signed.
  3. Written mandate: only after a positive review do we set down in writing which products are covered, which tasks we take on and how we keep each other informed.
  4. Ongoing support: you receive our details for labels and online offers. We keep the agreed documents ready for requests from the authorities, receive enquiries from market surveillance, follow Safety Gate alerts for your product categories and get in touch if your product may be affected.

We work with you in German, English, Turkish or Chinese. There are clear limits, too: we do not issue a certificate, we do not promise approval by a marketplace or any particular decision by an authority, and not every product is accepted. Your own duties as manufacturer remain in place.

Service packages and prices are listed on eugpsr.de. You can send a first enquiry directly through the form on this page.

Frequently asked questions about the responsible person

As a retailer in Germany, do I have to appoint a responsible person?

No, as a distributor you do not appoint anyone. You do, however, check the labelling before selling and, for manufacturers outside the EU, name the responsible person in your online offer. If you import goods yourself, you are the importer and can be the responsible person yourself.

Where must the responsible person’s details appear?

The name or registered trademark and the postal and email address belong on the product, its packaging, the parcel or a document supplied with it. If the manufacturer is not established in the EU, the responsible person’s name, postal address and email address also appear in the online offer.

Can a fulfilment warehouse simply take on the role?

Only as a last resort. A fulfilment service provider is responsible for the products it handles if no manufacturer, importer or authorised representative is established in the EU. A warehousing or shipping contract alone does not make it an authorised representative; that requires a written mandate from the manufacturer.

Does this rule also apply to toys or electrical equipment?

Yes. For toys, electrical equipment and other products with their own EU rules that the EU Market Surveillance Regulation expressly lists, the rule applies directly under that Regulation. The Product Safety Regulation extends the same rule to the other products it covers.

Can Grüner Baum GmbH be the responsible person for my product?

Yes, for manufacturers outside the EU Grüner Baum GmbH takes on the role as authorised representative. This requires a positive review of the product, documentation and supply chain and a written mandate for specific products. Acceptance is not automatic; the review starts with an enquiry through the form on this page.

Related

  • Technical documentation, explained
  • Required details in online listings
  • Guide to the Product Safety Regulation (GPSR)

Request a responsible person

Do you manufacture outside the EU and have no importer in the EU? Describe your products in the form below and we will reply by email. Our specialist page Responsible Person on eugpsr.de explains the full scope of the service.

Tell us what you want to sell in the EU

A few details are enough to start. We reply by email.

Fields marked * are required.

Prefer the detailed form with package selection? Open it on eugpsr.de

We use your details only to answer your request. See our privacy policy.

Your Responsible Person: Grüner Baum GmbH, HRB 52165, Amtsgericht Mainz, Vorstädter Str. 32, 55276 Oppenheim, Germany. Managing Director: Hatice Muazzez Bodur.

Legal basis

For every topic on this page, this table gives the exact legal reference with a link to the official text. References as of 5 October 2026.

TopicLegal referenceOfficial text
Duty to have a responsible business in the EU, details on the product, regular checksArt. 16(1) to (3) Regulation (EU) 2023/988 (GPSR)EUR-Lex
The four routes and the responsible person’s tasks; toys, electrical equipment and other productsArt. 4(2)(a) to (d), (3) and (5) Regulation (EU) 2019/1020EUR-Lex
Manufacturer, own brand, importer, authorised representative, fulfilment service providerArt. 3(8), (9), (10) and (12), Art. 13(1) GPSREUR-Lex
Written mandate of the authorised representative, copy for the authorities, minimum tasksArt. 10(1) and (2) GPSREUR-Lex
The manufacturer stays responsible; the distributor’s duty to checkArt. 9, Art. 12(1) GPSREUR-Lex
Responsible person in the online offerArt. 19(b) GPSREUR-Lex
Accident reports for manufacturers outside the EUArt. 20(4) GPSREUR-Lex
Fine for missing evidence or detailsSection 28(2) Nos. 24 and 25 ProdSGgesetze-im-internet.de (German)
Applying the Regulation in practiceEuropean Commission guidelines C/2025/6233Guidelines
Imprint Privacy Policy Terms & Conditions
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