Under safety regulations, like the General Product Safety Regulation (GPSR), if you're selling certain products to certain regions, such as the EU or Northern Ireland, you need to provide contact information for the manufacturer, and sometimes the EU Responsible Person to ensure product safety standards are met and maintained.
EU Responsible Person
An EU Responsible Person is a type of economic operator which is established in the EU. It is the entity in the EU who is responsible for certain tasks related to compliance and product safety. The following entities are accepted as EU Responsible Persons:
- Manufacturer, if based in the EU
- Authorized representative of the manufacturer in the EU
- Importer in the EU, if the manufacturer is not based in the EU
- A fulfillment service provider in the EU, for the products it handles, if there is no EU-based manufacturer, authorized representative, or importer
Their key tasks include:
- Verifying that the declaration of conformity / performance for a product has been created and is maintained according to legal requirements
- Verifying that the technical documentation of the product has been created and is provided to the market surveillance authorities on request
- Cooperating with relevant authorities to provide any other information to demonstrate product conformity as required
- Where an EU Responsible Person / economic operator has reason to believe that a product is not compliant or poses a health and safety risk to the public, it has to inform the authorities and take corrective action, whether by itself or by asking the manufacturer to do so
If there is an EU manufacturer or an EU authorized representative of the manufacturer, they are the EU Responsible Person. If there is no EU manufacturer, the importer is the EU Responsible Person. If there is no EU manufacturer, importer, or EU authorized representative, an EU fulfillment service provider can be designated as the EU Responsible Person.
Manufacturer
The manufacturer is the corporate entity that manufactured the product, or caused it to be manufactured. If the manufacturer has an established physical presence in the EU, then they are the EU Responsible Person.
Authorized representative
A manufacturer may authorize a representative to act on their behalf as an EU Responsible Person in the European Union.
If the manufacturer has appointed an authorized representative, obtain their name and contact details (including postal and email address) and ensure that the information is included in the listing and is indicated on the product or its packaging. If the non-EU manufacturer has not appointed an authorized representative in the EU, work with the manufacturer to appoint one. The authorized representative will need a mandate signed by the manufacturer and will need to obtain and keep the certificate of conformity / performance and other technical documentation from the manufacturer.
Importer
For the purposes of being the EU Responsible Person, an importer is the entity that imports the goods into the EU.
Fulfillment service provider
If there is no EU manufacturer, importer, or EU authorized representative, an EU fulfillment service provider can be designated as the EU Responsible Person.
Fulfillment service providers in the EU are specialist companies or persons in the EU that provide two or more of the following services:
- Warehousing
- Packaging
- Addressing
- Dispatching
Carriers and logistics service providers, which only handle shipment or movement of goods, are not fulfillment service providers.
If you want to use a fulfillment service provider in the EU, you can work with the manufacturer to provide relevant documents to them. If the fulfillment service provider accepts the documents and your goods, it will become the EU Responsible Person and you can then indicate their name or contact information (including postal and email address) in the listing and on the product or its packaging. However, some fulfillment service providers may ask for an authorized representative of your products instead. In this case, you would still need to work with the non-EU manufacturer to appoint an authorized representative in the EU.
Please note the information provided is for guidance only and does not constitute legal advice.
Adding contact information to your listings
Once you know the information of the manufacturer and/or the EU responsible person, you can add it to your listings.