EU representative for UK sellers: role, duties, costs under GPSR
On 13 December 2024, everything changed for UK sellers targeting European markets. The EU Product Safety Regulation (GPSR) requires you to appoint an EU-appointed representative — known as a Responsible Person. This is not optional: if you export products to the EU, you need this person as your designated authority contact. We show you who can be this person, what they must do, and why the costs — typically 150 to 500 Euro per year — are far less than the risk of fines up to 100,000 Euro.
Why UK trade and GPSR connect
Since the UK left the European Union, trading with EU member states requires longer routes and more bureaucratic control points. Not because authorities want to complicate matters unnecessarily, but because product safety is not optional. From December 2024, the General Product Safety Regulation (GPSR) requires every non-EU manufacturer — including you as a UK seller — to have a responsible contact established in the EU. In English, this role is called a Responsible Person; in German, an EU-bevollmächtigter Vertreter. You might wonder: why can't I fill this role myself? Theoretically, you can. Practically speaking, hiring a dedicated service provider is significantly less burdensome and carries considerably less risk.
Definition and role of the EU-Authorised Representative under GPSR
Under GPSR, the EU-bevollmächtigter Vertreter — often called an Authorised Representative or Responsible Person in English — is the natural or legal person you appoint as a non-EU manufacturer to discharge your product safety obligations. Not all of them — your primary responsibility partly remains yours. But this person serves as the contact point for authorities, the bridge between your business and EU regulators. They must be established or conducting business in the Union — a purely virtual representative does not suffice.
A product covered by this Regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020 in respect to that product.
This is not optional — it is mandatory. Anyone placing a product on the EU market must be able to demonstrate to authorities that a responsible Responsible Person is established with a seat or effective place of business in the Union. Fail to do so, and the product does not enter the market — and the company risks substantial fines. The logic is pragmatic: EU authorities want a local contact, not time delays and language barriers when product safety matters are at stake.
Obligations for UK sellers exporting to the EU
To be clear: you do not need a Responsible Person because your product is defective. You need one because you are not an EU-based company — and regulators want a local contact. In the UK, authorities such as Trading Standards manage compliance. The EU expects the same local accountability. For you as a UK seller, this means: you must be able to show that you have appointed a qualified Responsible Person. You do this by submitting a Designation Statement signed by both your company and the appointed person. Keep this document — regulatory inspections are coming. Additionally, GPSR requires your Responsible Person to maintain an operating base in the EU or to perform the necessary functions from there. Having an address on paper is insufficient — the person must be reachable.
What the EU-bevollmächtigter must actually do
The duties of a Responsible Person are defined by law. They must: (1) retain all technical documentation and make it available to authorities on request — for a minimum of ten years after the product enters the market; (2) manage the EU Declaration of Conformity and update it as necessary; (3) coordinate post-market surveillance — collecting reports of accidents, injuries or defects and submitting them to the competent authorities; (4) assist market surveillance authorities if they wish to test or examine the product; (5) manage and document market communication in the event of a recall. This is not merely an administrative function — it is genuine liability in your supply chain.
A Responsible Person plays a critical role in ensuring product safety and compliance, including: • Acting as the main contact for EU regulatory authorities. • Maintaining and managing compliance documentation. • Overseeing post-market surveillance, including incident reporting and recalls. • Addressing consumer safety concerns, complaints, and inquiries.
This is not a figurehead role. A mistake in documentation or a missed safety issue can have grave legal consequences for both your company and the appointed person — including substantial fines or, at worst, liability to consumers for damages.
Fines and consequences for non-compliance
GPSR has been valid in all EU member states since 13 December 2024, and with it, the associated penalties. In Germany, for example, the new Product Safety Act (ProdSG) sets out clear penalty ranges. Anyone who violates the regulation — for instance, by failing to appoint a Responsible Person or not registering their details correctly — can face fines up to EUR 100,000. This is the maximum penalty for serious administrative offences. Other breaches, such as incomplete or outdated documentation, incur fines of at least EUR 10,000. For comparison: annual costs for a dedicated Responsible Person service run between EUR 150 and EUR 500. The maths is straightforward.
In serious cases, such administrative offence can be punished with a fine of up to EUR 100,000. In other cases, only a fine of up to EUR 10,000 is provided for.
This is not fiction — it comes from current legal guidance by Baker McKenzie on Germany's implementing rules. Authorities are already conducting inspections — not out of spite, but because product safety is in the public interest. Market surveillance is routine in the EU. Compliance from day one beats paying EUR 100,000 later.
Costs and selection criteria for a service provider
A dedicated Responsible Person service costs between EUR 150 and EUR 500 per year, depending on the number of your products and the complexity of their technical documentation. Specialised compliance firms offer exactly this service. What should you look for? First: experience with UK sellers in your product category. Has the firm handled similar cases? Second: genuine responsiveness. A good Responsible Person is not merely a record store — they must be reachable during regulatory contacts. Third: transparency on add-on fees. Some providers charge extra for incident reports or documentation amendments. Ask explicitly in writing: what is included, and what is extra? A bargain Responsible Person is only cheap if it does not turn expensive later.
Which products fall under GPSR (and which do not)
Not every product requires a Responsible Person under GPSR. The regulation generally covers all consumer products reaching end-users — from toys to furniture to electronics. Exceptions apply to goods covered by specialist frameworks: vehicles (their own rules), food (food law), medicines (pharmaceutical law), or highly specialised industrial machinery. Unsure about your product? The IHK München has published a helpful FAQ, and the UK government (GOV.UK) provides specific guidance for UK exports to the EU. Key point: once you cross into the EU market, GPSR applies — regardless of which rules govern your product in the UK.
1. EUR-Lex — Regulation (EU) 2023/988 (GPSR) 2. IHK München — FAQ on the new General Product Safety Regulation 3. Baker McKenzie — Germany Aligns Product Safety Law with EU 4. GOV.UK — EU Regulation 2023/988 on General Product Safety: detailed guidance 5. Euverify — EU Responsible Person Under GPSR: Role, Requirements & Service Costs 6. BAuA — Product Safety Act
Conformis does this for you
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Häufige Fragen
What is the difference between manufacturer and Responsible Person?⌄
Your UK company remains the original responsible person for product safety. The Responsible Person is an additional operator in your supply chain whom you must involve closely. They handle specific tasks: documentation, regulatory communication, and post-market monitoring. But final responsibility stays partly with you. Crucially, if a liability claim arises, both you and your appointed representative can face liability. Careful selection matters. A good Responsible Person isn't an alibi — it's a genuine safety net for your EU business.
Can a UK company provide its own Responsible Person?⌄
Technically yes, but rarely practical. A Responsible Person must have a place of business in the EU or be able to operate there. If you're a UK seller without an EU office, you'd need to post one of your staff there or hire locally — that quickly costs more than a service provider. Moreover, the role demands specialised knowledge that external providers possess routinely. Most successful UK sellers opt for a dedicated service rather than an in-house solution.
How much does an EU Responsible Person service cost per year, and are hidden costs common?⌄
Standard costs range from €150 to €500 per year, depending on how complex your product portfolio is and how often you need technical documentation updated. Some providers charge extra for special cases: incident reporting, complex recalls, or extraordinary documentation. It's legal, but frustrating if you don't know beforehand. When requesting a quote, ask explicitly: are incident reports included? Do regulatory enquiries cost extra? How many Declaration of Conformity updates per year come with the fee? This prevents nasty surprises at year-end.
Do I need to register my Responsible Person separately in each EU country?⌄
No. Your Responsible Person just needs to be established or operating in one EU country. From there, they can serve as your regulatory contact point across all EU markets — at least at GPSR level. However, some Member States impose additional local requirements, such as registration with national enforcement authorities. Clarify this with your service provider. Good news: specialised providers handle these compliance details routinely and know which extra steps are required in each country.
What happens if my Responsible Person becomes unavailable or the working relationship ends?⌄
That's a legitimate concern. You need a replacement quickly. There can't be a gap where no responsible contact point is available to authorities. Most service contracts have a three- or six-month notice period — some allow monthly termination. When the relationship ends, you should have already appointed a new Responsible Person before the old one leaves. Some providers also help with the transition and hand over documentation in an organised way. Recommendation: sort out these details before signing, not when you're under pressure.
Do I need a separate Responsible Person for each product, or is one enough for all?⌄
One Responsible Person can cover multiple products — that's the standard. A service provider can manage your entire product range, not just specific categories. Some providers price based on the size of your range and how often technical documentation needs updating. A Responsible Person for ten simple products (say, different silicone kitchen utensils) might cost €150 per year; one for 200 complex products with frequent updates would be closer to €500. This is market standard and should be clearly stated in your quotation.
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