Start with the terminology. Under the General Product Safety Regulation (EU) 2023/988, a product within scope may be placed on the Union market only when an economic operator established in the EU is responsible for the prescribed tasks. An authorised representative is a manufacturer-appointed party with a written mandate for specified tasks. An authorised representative can also be the responsible person, but GPSR is not a universal “authorised representative certificate” requirement.

For a non-EU manufacturer or brand, the practical review is product-specific: identify the responsible economic operator, document the mandate or commercial relationship, link the product to its technical evidence, and make the required identity and safety information visible on the product chain and in the online offer. A supplier’s generic test report does not replace that chain.

1. Responsible person and authorised representative are not the same concept

Article 16 of GPSR requires an economic operator established in the Union to be responsible for the relevant product. Depending on the manufacturer’s location, import route and other applicable Union legislation, that operator may be an EU manufacturer, an importer, an authorised representative with the required written mandate, or a fulfilment service provider where no other suitable operator is established in the Union. The correct role must be determined from the actual supply chain.

Under Article 16, the responsible operator must handle the tasks referred to in Article 4(3) of Regulation (EU) 2019/1020 and, where appropriate, regularly check that the product is supported by the technical documentation and meets the GPSR requirements for labelling and information. It must be able to provide documented evidence of those checks when market surveillance authorities request it. Its name or registered trade name/trademark and postal and electronic address must appear on the product, packaging, parcel or an accompanying document.

Article 10 addresses authorised representatives. A manufacturer may appoint one through a written mandate. The representative performs the tasks in that mandate, provides a copy of the mandate on request, informs the manufacturer when it considers or has reason to believe that a product is dangerous, and cooperates with authorities on risk-reduction actions. The mandate should define the manufacturer, products, tasks, document access and change process.

2. Confirm scope before building a document pack

GPSR is the general consumer-product safety framework for products placed or made available on the Union market, subject to its scope and exclusions. Products may also be primarily or additionally governed by sector-specific Union legislation. Toys, radio equipment, personal protective equipment, machinery, batteries, cosmetics and food-contact products cannot be reduced to a single GPSR responsible-person checklist.

Create a model- or SKU-level scope table covering the manufacturer and brand, product identifiers, destination Member States, import route, applicable sector legislation, responsible operator, required warnings and the location of supporting technical evidence. HS or CN codes can help with logistics and regulatory screening, but they do not prove product safety or GPSR compliance on their own.

Online sales, imports and EU fulfilment arrangements can distribute responsibilities across different economic operators. Do not treat a warehouse address, marketplace store address or shared mailbox as proof of the responsible person. Confirm the operator’s EU establishment, its actual mandate or role, and whether the name and contact details can remain consistent across the product information chain.

3. Evidence the responsible operator should be able to review

  • Product identification: model, batch, serial number, SKU, product image and packaging version must reconcile, with version records for design, factory or packaging changes.
  • Risk and technical documentation: the manufacturer’s risk analysis, design and manufacturing information, test or calculation basis, intended use, limitations, instructions and warnings should be traceable to the product. Article 9 places the technical-documentation duty on the manufacturer; a blank checklist is not a substitute.
  • Entity and address control: the legal name, registered trade name/trademark, postal address and electronic address of the manufacturer, importer and responsible operator should match across the documents. A written mandate should identify the authorised representative’s product and task scope.
  • Labels and language: responsible-operator details and product identifiers must be placed as required on the product, packaging, parcel or accompanying document. Instructions and warnings must use language consumers can readily understand in the Member State where the product is made available.
  • Ongoing records: keep complaint, accident, recall and corrective-action records, and show which SKU, package, listing and warehouse batch was affected by a change. Do not replace the applicable legal retention and notification rules with a universal “24-month validity” rule.

4. The online offer needs more than a certificate

Article 19 requires a clear and visible online or distance-sale offer to show at least four groups of information: the manufacturer’s name and postal and electronic address; where the manufacturer is outside the EU, the responsible person’s name and postal and electronic address; information identifying the product, including its picture, type and other identifiers; and applicable warnings or safety information.

Review the offer SKU by SKU. Do not hide responsible-person information only in a store home page, after-sales page or an image that cannot be searched or expanded. The model, picture, variant, warnings and packaging file should describe the same product. If sector-specific legislation requires more information, the GPSR minimum does not replace it.

Marketplace fields and review rules are operational requirements, not proof of a single EU-wide advance-review window, fixed report validity period or automatic delisting outcome. Keep legal requirements, marketplace fields and a buyer’s private audit checklist in separate columns.

5. A minimum review sequence for non-EU sellers

  1. Confirm the product category, manufacturer, destination Member States and import route for each model or SKU.
  2. Identify the responsible economic operator and collect its legal name, EU address, electronic address and actual mandate or commercial basis.
  3. Compare that identity and address across the product, packaging, parcel/accompanying document and online offer.
  4. Verify that the risk analysis, technical documentation, test basis, instructions, warnings and identifiers relate to the current product version. Supplier documents are only part of the evidence.
  5. Set up complaint, accident, recall, corrective-action and change records, with named owners for notifications, document delivery and authority cooperation.
  6. Where toys, radio equipment, machinery, batteries or another sector regime also applies, review its economic-operator, conformity-assessment, technical-file and marking rules separately.

6. Four recurring mistakes

Treating an authorised representative as a universal certification. The representative or responsible operator does not replace the manufacturer’s design, risk-assessment, testing or instruction duties.

Using a supplier certificate as the whole evidence chain. The entity, model, sample, standard version and conclusion in a report must correspond to the product being offered. A stamp or laboratory name alone does not establish that link.

Turning GPSR into a customs or marketplace guarantee. GPSR addresses product safety and economic-operator duties. Marketplace review, customs procedure, Member State enforcement and a buyer’s private standard have separate boundaries; do not promise release, approval or continued listing.

Replacing legal analysis with a fixed deadline. This guide does not impose a universal “24-month report”, “upload three to six months early” or “2%–5% of turnover” rule. Retention, notification, corrective action and sanctions must be checked against the applicable legislation, Member State rules and facts.

7. Sources and limits

This article reflects official texts checked on 21 August 2026 and is not legal advice for a particular product. The main sources are the current consolidated text of Regulation (EU) 2023/988 on EUR-Lex (including Articles 9, 10, 16, 19 and 20), Article 4 of Regulation (EU) 2019/1020 on EUR-Lex, and the European Commission Product safety page. Before placing a product on the market, review the product category, sales route, Member State language requirements and applicable sector legislation.