Who Can Be the GPSR Responsible Person?
Reviewed by Hatice Muazzez Bodur · Managing Director & Co-Founder, Grüner Baum GmbH
Published: September 1, 2026 · Updated: September 1, 2026
Article 16 in plain terms
Article 16 of the GPSR requires every product within its scope to have one economic operator established in the European Union who is responsible for a defined set of safety and compliance tasks. The regulation does not fix which company in a supply chain takes on that role. It sets out, in order, who is eligible and under what conditions.
The EU manufacturer
When a product is made by, or placed on the market under the name or trademark of, a company established in the EU, that manufacturer already carries the Article 16 tasks as part of its existing manufacturer duties. No separate appointment is needed for that supply chain.
The importer bringing the product into the EU
When a non-EU manufacturer's product enters the EU market through an EU-based importer, that importer typically becomes the Article 16 economic operator for the specific consignment and product line, in addition to the importer duties it already carries under the regulation.
The authorised representative, appointed in writing
A manufacturer established outside the EU may appoint an authorised representative established in the EU by written mandate. The appointment does not remove any importer duties that arise in the supply chain. For the representative to serve as the Article 16 responsible economic operator, the written mandate must cover the relevant Article 4(3) tasks and clearly identify the products and tasks accepted: keeping technical documentation available, providing it to an authority on request, informing the manufacturer of complaints and safety incidents, and cooperating with market surveillance action.
The fulfilment service provider, only under specific conditions
A fulfilment service provider can take on the Article 16 role only where no manufacturer, importer, or authorised representative established in the EU exists for that product. Even then, its Article 16 duties are limited to what the regulation assigns it. A warehousing or shipping contract does not, by itself, create a general responsible-person mandate.
How Grüner Baum GmbH reviews a mandate
Before Grüner Baum GmbH agrees to take on an Article 16 role for a product, we review the product category, any additional EU rules that apply beyond the GPSR, the technical documentation already available, and where the product currently sits in the supply chain. A written, product-specific agreement follows only where that review is positive. The role does not start on the strength of a website visit or a general enquiry.
Grüner Baum GmbH's EU GPSR Responsible Person service on eugpsr.de
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Next step
If you need to establish who carries the Article 16 role for a specific product, this review starts on eugpsr.de.