EU Responsible Person
An entity established in the EU that is accountable to authorities for a product's compliance and can be contacted directly.
Aliases: EU RP, Responsible Person, Authorised Representative, 欧盟责任人, 欧代
Definition and legal basis
An EU responsible person is an entity established inside the Union that takes on defined compliance duties for a product placed on the EU market by a manufacturer based outside it. The concept appears in several instruments; the most cited are Article 16 of the GPSR and Regulation (EU) 2019/1020 on market surveillance.
The role is not a mailbox. Authorities expect the person to hold or be able to obtain the technical documentation, to answer questions within a short deadline, and to act when a product turns out to be unsafe.
What the person actually does
- Verify that the declaration of conformity and technical file exist and are complete
- Keep the documentation available for market surveillance authorities
- Cooperate on corrective action, withdrawal or recall
- Provide authorities with information on risks and on the supply chain
- Appear as the contact point on the product, packaging or listing
Under the GPSR the name, registered trade name or trademark, postal address and email of the responsible person must be visible. For distance sales, that means the product page, not only the carton.
Who can be appointed
An importer, an authorised representative with a written mandate, a fulfilment service provider, or a specialist compliance company. The appointment must be in writing and must state which products and which duties are covered. A responsible person cannot outsource accountability to the seller: if the file is missing, the person established in the EU is the one the authority calls.
Where the arrangement breaks
Three failure patterns recur. The mandate covers a product family that no longer matches the shipped SKUs. The documentation is held by the factory and never reaches the EU entity. The contact details on the listing point to a marketing address that does not answer compliance queries.
A workable structure separates evidence from marketing: a technical file the EU entity can access within 24 to 48 hours, a named contact with authority correspondence experience, and a review triggered whenever a product or supplier changes.
Relationship to other obligations
The responsible person does not remove the need for product testing, for CE marking where a directive applies, or for registration duties such as EPR. It also does not guarantee that a platform will accept an account. Marketplaces run their own seller verification checks, and a compliant RP is one input among several.
Primary source: Regulation (EU) 2023/988, Article 16; Regulation (EU) 2019/1020.