How to Appoint an EU Responsible Person

1. Why You Need an EU-Based Contact Person

If your business is based outside the European Union, you cannot directly fulfil EU compliance obligations for products you sell on the EU market. EU law requires that an entity physically established within the EU be responsible for product safety and regulatory communication with market surveillance authorities. Without this EU-based entity, your products cannot legally be placed on the EU market.

Two separate EU regulations create this requirement, each with its own terminology and obligations:

• Regulation (EU) 2023/988 — the General Product Safety Regulation (GPSR), Article 15, requires non-EU manufacturers to designate an Authorised Representative (AR) for consumer products sold in the EU
• Regulation (EC) No 1223/2009 — the EU Cosmetics Regulation, Article 4, requires every cosmetic product placed on the EU market to have a designated Responsible Person (RP) established in the EU

These are legally separate roles with different obligations, different legal bases, and different scopes. However, a single entity can fulfil both roles if it has the necessary expertise and agrees to accept both mandates. For many non-EU sellers, appointing one provider for both roles is the most practical approach.

2. GPSR Authorised Representative (Article 15)

The General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) replaced the older General Product Safety Directive and has applied since December 13, 2024. Under Article 15, non-EU manufacturers must designate an Authorised Representative established in the EU before placing consumer products on the EU market.

Who Needs a GPSR Authorised Representative?

Every non-EU manufacturer selling consumer products directly to EU consumers — whether through their own website, online marketplaces, or via EU importers — must ensure an AR is designated. This applies to all non-food consumer products: candles, homeware, textiles, electronics, toys, cosmetics (in addition to cosmetics-specific requirements), and more.

Requirements for the AR

• Physical postal address in the EU — PO boxes do not count; it must be a street address where the AR can receive correspondence and where market surveillance authorities can contact them
• Name and contact details on the product — the AR's name, registered trade name or trademark, and postal address must appear on the product, its packaging, or an accompanying document
• The AR must be appointed by means of a written mandate from the manufacturer

Obligations of the GPSR Authorised Representative

• Hold and provide technical documentation and the EU declaration of conformity to market surveillance authorities on request
• Cooperate with market surveillance authorities and provide information and documentation to demonstrate product conformity
• Inform the manufacturer immediately about complaints from consumers and authorities
• Take corrective action (or ensure the manufacturer does) when the AR has reason to believe a product is not safe or does not comply
• Upon reasoned request from an authority, provide all information necessary to demonstrate product safety

Key Date

The GPSR has applied since December 13, 2024. Products placed on the EU market after this date must comply with all GPSR requirements, including the AR designation. There is no transition period — enforcement is active now.

3. Cosmetics Regulation Responsible Person (Article 4)

The EU Cosmetics Regulation (Regulation (EC) No 1223/2009, Article 4) requires that every cosmetic product placed on the EU market has a designated Responsible Person (RP) who is established within the EU. This has been in force since 2013 and is not new — but many small non-EU sellers are only now discovering this requirement as they begin selling internationally.

What Counts as a Cosmetic Product?

The definition is broad. Under the EU Cosmetics Regulation, a "cosmetic product" is any substance or mixture intended to be placed in contact with the external parts of the human body (skin, hair, nails, lips, external genital organs) or with the teeth and mucous membranes of the oral cavity, for the purpose of cleaning, perfuming, changing appearance, protecting, or keeping in good condition.

• Skincare (moisturisers, serums, cleansers, sunscreen)
• Makeup (foundation, lipstick, mascara, eyeshadow)
• Hair care (shampoo, conditioner, hair dye, styling products)
• Soap classified as a cosmetic (most handmade soaps making skin-benefit claims)
• Perfume and fragrance applied to the body
• Nail polish and nail care products
• Oral care products (toothpaste, mouthwash)
• Bath products (bath bombs, bath salts, bubble bath)

Obligations of the Cosmetics Responsible Person

The RP role under the Cosmetics Regulation is more onerous than the GPSR AR role. It requires cosmetics-specific expertise and involves significantly more documentation and regulatory interaction.

• Cosmetic Product Safety Report (CPSR): The RP must ensure a CPSR exists for each product before it is placed on the market. The CPSR must be prepared by a qualified safety assessor
• Good Manufacturing Practice (GMP): The RP must ensure the cosmetic is manufactured in accordance with GMP (ISO 22716)
• Product Information File (PIF): The RP must maintain a PIF for each product, containing the product formula, CPSR, manufacturing method description, proof of claimed effects, and animal testing data
• CPNP notification: The RP must notify the Cosmetic Products Notification Portal (CPNP) before the product is placed on the EU market
• Labeling compliance: The RP must ensure all labeling requirements are met, including INCI ingredient lists, batch numbers, PAO or expiry dates, function, and warnings
• Serious undesirable effects: The RP must report serious undesirable effects to the competent authority of the Member State where the effect occurred

4. GPSR AR vs. Cosmetics RP — Key Differences

While both roles require an EU-established entity to act on behalf of a non-EU business, the scope, obligations, and expertise requirements differ significantly.

Do You Need Both?

If you sell cosmetic products in the EU, you almost certainly need both designations. The GPSR includes a broad safety-net clause (Article 2(1)) that applies to consumer products not covered by sector-specific Union harmonisation legislation — and whether cosmetics are fully excluded from GPSR scope is legally debated. In practice, EU marketplace enforcement treats both as required. Amazon EU, for example, requires both GPSR AR details and a Cosmetics RP for cosmetic product listings.

The safest approach: appoint one entity that can serve as both your GPSR Authorised Representative and your Cosmetics Responsible Person. Many compliance service providers offer combined packages specifically for this purpose.

5. Who Can Serve as Your Responsible Person?

Any natural or legal person established in the EU can technically serve as your AR or RP. In practice, the choice depends on your product type, budget, and how much compliance support you need.

Option A: Specialized Compliance Service Providers

Companies that offer AR/RP as a dedicated service. This is the most common choice for small to mid-sized non-EU sellers. These providers typically handle documentation storage, CPNP notifications, authority liaison, and label review as part of their service.

Option B: Your EU Distributor or Wholesaler

If you sell through an EU-based distributor, they can agree to act as your RP. Be aware that this means they take on legal liability for your products — many distributors are reluctant to accept this role without significant assurances about product quality and documentation.

Option C: Your EU-Based 3PL / Fulfilment Partner

Some third-party logistics providers that warehouse and ship your products within the EU also offer AR/RP services as an add-on. This can be convenient because they already handle your physical inventory and may be able to apply corrected labels or hold non-compliant stock.

Option D: A Legal Firm or Trade Compliance Consultancy

Regulatory law firms and trade compliance consultancies sometimes offer AR/RP services, particularly for businesses with complex product portfolios or high-risk product categories. This is the most expensive option but may be appropriate for businesses facing specific regulatory challenges.

Option E: An Individual Person Residing in the EU

Technically, a natural person (an individual) established in the EU can serve as your AR or RP. This is rare and generally only suitable for very small operations — the individual assumes personal legal liability, which is a significant commitment.

Comparison of Options

6. How to Appoint an AR/RP — Step by Step

Step 1: Determine Which Roles You Need

Start by identifying which regulations apply to your products. If you sell any consumer product in the EU, you need a GPSR Authorised Representative. If you sell cosmetic products, you also need a Cosmetics Responsible Person. If you sell both cosmetic and non-cosmetic consumer products, you need both roles covered — though one entity can handle both.

Step 2: Choose Your Entity Type

Review the options in Section 5 and select the type of provider that best fits your budget, product complexity, and growth plans. For most small sellers, a specialized compliance service provider offers the best balance of cost and capability.

Step 3: Execute a Written Mandate / Contract

The GPSR explicitly requires a written mandate from the manufacturer to the AR. For the Cosmetics RP, a formal contract or agreement defining the scope of responsibilities is essential. The contract should clearly specify: which products are covered, which obligations the AR/RP accepts, liability allocation, termination terms, and documentation handover procedures.

Step 4: Provide All Required Documentation

Your AR/RP cannot fulfil their obligations without your documentation. Provide:

• For GPSR AR: Technical file, test reports, EU declaration of conformity, product descriptions, risk assessments
• For Cosmetics RP: Product formulas, CPSR (or commission one), GMP evidence, manufacturing method descriptions, proof of claimed effects, stability testing data
• Safety Data Sheets (SDS) for any chemical products
• Current product labels and packaging artwork for review

Step 5: Update Product Labels and Packaging

Once your AR/RP is appointed, update your labels to include their name and EU postal address. This is a mandatory labeling element — products without it can be refused entry to the EU market or removed from marketplace listings. Plan for print lead times and existing inventory.

Step 6: Register the Designation

• For GPSR: Register the AR designation through the economic operator registration system. Some Member States are implementing dedicated portals for this
• For Cosmetics: The RP must submit the CPNP notification for each product before it is placed on the market. The CPNP notification names the RP and cannot be completed without one

Step 7: Establish Ongoing Communication Protocols

Appointing an AR/RP is not a one-time task. You need ongoing processes for:

• Forwarding consumer complaints and adverse event reports
• Communicating product changes (new formulations, new products, discontinued products)
• Coordinating corrective actions if a safety issue arises
• Receiving regulatory updates that affect your products
• Annual documentation reviews and updates

7. What Goes on the Label

Under GPSR Article 9(7), the manufacturer (or the AR acting on their behalf) must indicate on the product their name, registered trade name or trademark, and the postal address at which they can be contacted. For non-EU manufacturers, the AR's address serves as this contact point — so the AR's information effectively replaces the manufacturer's address on the label. The required information includes:

• Name: The full legal name or registered trade name of the AR/RP entity
• Postal address: A full street address in the EU — not a PO box. Must include street, city, postal code, and country
• Contact details (recommended): Email address and/or phone number. Not strictly required by all regulations but increasingly expected by marketplace platforms and authorities

GPSR Label Format

For GPSR compliance, the AR's details can be preceded by identifying text. Common formats include:

Cosmetics Regulation Label Format

The Cosmetics Regulation does not prescribe a specific prefix, but the RP must be clearly identifiable on the label. Many sellers use a format like:

Practical Considerations

• If one entity serves as both your GPSR AR and Cosmetics RP, you can list them once with a combined label such as "EU Responsible Person / Authorised Representative"
• The address must be kept up to date — if your AR/RP changes address, you must update all labels
• For products with small packaging, the information may be placed on an outer box, leaflet, or tag — but it must always accompany the product
• Many sellers print AR/RP details on a sticker applied to the product during EU fulfilment, avoiding the need to maintain separate packaging runs for EU vs. non-EU markets

8. Costs and What to Expect

Pricing varies significantly depending on whether you need AR-only (GPSR), full Cosmetics RP services, or both, and on the number of products in your portfolio.

Typical Pricing Ranges

What a Good AR/RP Provider Should Offer

• Regulatory monitoring: Proactive alerts about regulatory changes that affect your products
• Label review: Verification that your product labels meet EU requirements before you print
• Document storage: Secure storage of your technical files, PIFs, CPSRs, and declarations of conformity
• Authority liaison: Direct communication with market surveillance authorities on your behalf
• Annual compliance check: Periodic review of your product documentation to ensure ongoing compliance
• CPNP management: (For cosmetics RP) Handling all CPNP submissions and updates

Be wary of providers charging significantly below these ranges — an AR/RP that does not actually hold your documentation or respond to authority requests leaves you exposed. The cheapest provider is not always the best value if they fail to fulfil the core obligations.

9. Online Marketplace Enforcement

EU online marketplaces are actively enforcing GPSR Authorised Representative requirements. Since December 13, 2024, compliance is not just a legal obligation — it is a practical requirement to maintain your product listings.

Amazon EU

• Amazon requires AR details in product listings via the "EU Responsible Person" field in Seller Central
• Listings without AR information can be suppressed, made inactive, or removed entirely
• Amazon may verify the AR address and contact details
• For cosmetic products, Amazon requires both GPSR AR and Cosmetics RP information
• Non-compliant ASINs may be flagged during routine compliance sweeps

Other Marketplaces

• Etsy: Has implemented GPSR compliance fields for EU-facing listings; sellers must provide AR details for products sold to EU buyers
• eBay: Rolling out GPSR compliance requirements across EU sites; enforcement is expected to tighten throughout 2025-2026
• Shopify: Does not enforce directly, but sellers using Shopify to sell into the EU remain subject to GPSR and must ensure compliance independently

What Happens Without Compliance

If you sell on EU marketplaces without a designated AR, the consequences are immediate and practical:

• Product listings suppressed or deactivated — you lose visibility and sales
• Account-level warnings or restrictions for repeated non-compliance
• Products held at EU customs if imported without compliant labeling
• Market surveillance authorities can order product withdrawal from the EU market
• Fines vary by Member State but can reach tens of thousands of euros per infringement

10. Compliance Checklist

Determination

• Identify whether your products are consumer products (GPSR applies) or cosmetics (Cosmetics Regulation applies) or both
• Confirm that you are a non-EU manufacturer or seller placing products on the EU market
• Determine whether you need a GPSR AR, a Cosmetics RP, or both
• Review your product portfolio to confirm which products require which designations

Appointment

• Select an AR/RP provider or entity (see Section 5 for options)
• Execute a written mandate or contract defining scope, responsibilities, and liability
• Provide the AR/RP with all required technical documentation, PIFs, CPSRs, and test reports
• Confirm the AR/RP has a valid EU postal address (not a PO box)
• For cosmetics: ensure the RP has submitted CPNP notifications for each product

Labeling

• Update product labels to include the AR/RP name and EU postal address
• Verify label format meets GPSR and/or Cosmetics Regulation requirements
• Plan for existing inventory — apply stickers, relabel, or sell through before the next print run
• Confirm labels are accurate across all product variants and packaging sizes

Ongoing

• Establish a process for forwarding consumer complaints and adverse events to your AR/RP
• Notify your AR/RP of any product changes (new products, formula changes, discontinued items)
• Update marketplace listings (Amazon, Etsy, eBay) with correct AR/RP details
• Schedule an annual compliance review with your AR/RP provider
• Monitor regulatory updates — GPSR implementing guidance is still evolving in 2026

11. Common Mistakes

These are the errors that most frequently cause compliance failures, marketplace listing removals, or enforcement action when appointing an EU Responsible Person or Authorised Representative.

Using a Non-EU Address

The AR/RP must be established in the EU. A US, UK, or other non-EU address does not satisfy the requirement — even if the person or entity has EU clients. Post-Brexit, a UK address no longer qualifies. The address must be in one of the 27 EU Member States.

Using a PO Box

Both GPSR and the Cosmetics Regulation require a postal address where authorities can physically reach the AR/RP. A PO box does not meet this requirement. The address must be a street address where the entity can receive correspondence and, if necessary, be visited by market surveillance authorities.

Confusing the GPSR AR with the Cosmetics RP

These are different legal roles with different obligations. Appointing an entity as your GPSR AR does not automatically make them your Cosmetics RP. If you sell cosmetics, you need a specific RP designation under Regulation (EC) No 1223/2009, with the corresponding obligations (CPNP, PIF, CPSR). Make sure your contract explicitly covers both roles if you need both.

Appointing an AR/RP Without Providing Documentation

An AR/RP cannot fulfil their obligations without your technical documentation. If a market surveillance authority requests your technical file and your AR cannot produce it, both you and the AR are in breach. Provide all required documentation at the time of appointment, not "later when needed."

Not Updating Labels When Changing AR/RP

If you switch AR/RP providers, all product labels must be updated to reflect the new entity's name and address. Products with outdated AR/RP information are non-compliant. Plan for label transition when changing providers — do not leave old inventory circulating with incorrect information.

Assuming Your Freight Forwarder Is Your AR

A freight forwarder, customs broker, or shipping agent is not automatically your Authorised Representative. The AR must be formally designated through a written mandate and must accept the specific legal obligations. Simply having a logistics partner in the EU does not satisfy the AR/RP requirement unless they have explicitly agreed to serve in that capacity.