EU Representative for UK Sellers: Role, Duties, Costs under GPSR
13 December 2024 brought significant changes for UK Sellers selling in European markets. The EU Product Safety Regulation (GPSR) requires them to appoint an EU Representative — a Responsible Person. This is not optional: anyone exporting products to the EU must have this point of contact for authorities. We show who qualifies, what this role involves, and why the costs — typically €150 to €500 per year — are minimal compared with the risk of fines up to €100,000.
Why UK trade and GPSR are connected
Since the UK left the European Union, trading with EU countries now requires longer routes and more regulatory checkpoints. Not because authorities want to be unnecessarily complicated, but because product safety is not optional. From December 2024, the EU's General Product Safety Regulation (GPSR) creates a ruleset requiring every non-EU manufacturer — including you as a UK seller — to have a responsible contact person on the ground. A Responsible Person, as it sounds in English — or in German: an EU-authorised representative. You might wonder: why can't I simply fill this role myself? In theory, you can. In practice, the alternative — engaging a dedicated service provider — is far less burdensome and risky.
Definition and role of the EU-authorised representative under GPSR
The EU-authorised representative — often called Authorised Representative or Responsible Person in English — is under GPSR the natural or legal person you appoint as a non-EU manufacturer to handle your product-safety obligations. Not all obligations — your primary responsibility remains partly with you. But this person becomes the contact point for authorities, the interface between your business and European regulators. They must be established or active in the Union — a purely virtual representative is not enough.
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 guidance, but a binding requirement. Anyone bringing a product into the EU must be able to demonstrate to authorities that a responsible Responsible Person with an office or active place of business exists in the Union. Otherwise the product stays off the market — and you risk fines. The principle is pragmatic: EU authorities want a local contact, not time zone delays and language barriers on product safety.
UK sellers' obligations when selling into the EU
Let's be clear: you don't need a Responsible Person because your product is bad. You need one because you are not an EU business — and regulators want a local contact. In the UK, authorities like Trading Standards manage your compliance. In the EU, it must be equally local. For you as a UK seller, that means specifically: you must show that you have appointed a qualified Responsible Person. This happens via a Designation Statement that both your company and the appointed person sign. You must have this document ready — regulatory inspections will happen. Furthermore, GPSR requires that this person has a place of business in the EU or can actually carry out the necessary functions there. Simply having an address on paper is not enough — the person must be reachable.
What the EU-authorised representative must actually do
A Responsible Person's duties are defined by law. They must: (1) Keep all technical documentation and provide it to authorities on request — for at least ten years after the product is placed on the market. (2) Manage the EU Declaration of Conformity and update it if needed. (3) Coordinate post-market surveillance — collect reports of accidents, injuries or defects and report them to the relevant authorities. (4) Support market surveillance authorities if they wish to test or inspect the product. (5) Handle and document communication with the market in case of a recall. This is not simply an administrative job — it is genuine responsibility in the 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 box-ticking exercise. A documentation error or an overlooked safety defect can have serious legal consequences for your company and the appointed person — up to fines or in extreme cases claims for damages from consumers.
Fines and consequences for non-compliance
GPSR has been valid in all EU Member States since 13 December 2024, and with it the attached sanctions. In Germany, for example, the new Product Safety Act (ProdSG) established clear penalty frameworks. Anyone breaching the regulation — for example by not appointing a Responsible Person at all, or by failing to register their data correctly — can face fines of up to €100,000. That is the maximum penalty for serious breaches. Other violations, such as incomplete or outdated documentation, incur fines of at least €10,000. For comparison: annual costs for a dedicated Responsible Person service range from €150 to €500. The maths is simple.
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 from a crime series, but from current legal advice by Baker McKenzie on Germany's implementation rules. Authorities are already inspecting — not because they are malicious, but because product safety is a matter of public interest. Market surveillance is standard practice in the EU. It is better to be compliant from the start than to pay €100,000 later.
Costs and selection criteria for a service provider
A dedicated Responsible Person service costs you between €150 and €500 per year — depending on how many products you have and how complex their technical documentation is. There are specialist compliance service providers offering exactly this. What should you look out for when shopping around? First: experience with UK sellers and your product category. Has the provider already worked on comparable cases? Second: genuine availability. A good Responsible Person is not simply a filing system — this person must also be reachable during regulatory contacts. Third: transparency on additional costs. Some providers charge extra for incident reports or particular documentation changes. Ask in the quote explicitly: what is included, and what costs extra? A cheap EU Responsible Person is only cheap if it does not become expensive later.
Which products fall under GPSR (and which don't)
Not every product needs a Responsible Person under GPSR. The regulation generally covers all consumer products that reach end users — from toys to furniture to electronics. Exceptions are goods falling under specialist regimes: vehicles (have their own rules), food (food law), medicines (pharmaceutical law) or highly specialist machinery in industrial contexts. If you are unsure whether your product falls under it: the IHK München has put together a helpful FAQ; the British Government (GOV.UK) also offers specific guidance for UK exports into the EU. Remember: once you cross the EU border, GPSR applies — even if your product is subject to different rules in the UK.
1. EUR-Lex — Verordnung (EU) 2023/988 (GPSR) 2. IHK München — FAQ zur neuen Produktsicherheitsverordnung 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 — Produktsicherheitsgesetz
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What's the difference between a manufacturer and a Responsible Person?⌄
The manufacturer — 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 closely engage. They handle specific tasks such as documentation, regulatory communication, and post-market surveillance, but final accountability remains partly with you. Importantly: if liability arises, both you and your appointed representative can be held liable. That's why careful selection is critical. A good Responsible Person isn't a rubber stamp, but a genuine safety net for your EU business.
Can a UK business appoint its own Responsible Person?⌄
Technically yes, practically rarely worthwhile. 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 send one of your staff there or hire someone new — that quickly costs more than hiring a service provider. Moreover: the regulatory requirements demand specialised knowledge that external service providers have routinely. Most successful UK sellers therefore 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 fees common?⌄
Standard costs range from €150 to €500 per year, depending on your product portfolio's complexity and how often technical documentation needs updating. Some providers charge separately for edge cases such as incident reporting, complex recalls, or extraordinary documentation. That's legal, but frustrating if you don't know in advance. When seeking a quote, ask directly: are incident reports included? Do regulatory enquiries cost extra? How many declarations of conformity revisions per year are in the fee? This way you avoid nasty surprises at year-end.
Do I need to register my Responsible Person individually in every EU country?⌄
No. It's enough for your Responsible Person to be resident or active in one EU country. From there, they serve as the regulatory interface for all EU markets — at least at GPSR level. However: some member states have additional local requirements, such as registration with national monitoring authorities. You should clarify this with your service provider. The good news: specialised service providers routinely manage these compliance details and know which additional steps are needed in which countries.
What happens if my Responsible Person leaves or the arrangement ends?⌄
That's a legitimate concern. The straightforward answer: you need a replacement fast. There can't be a gap where no accountable contact is available to regulators. Most service contracts have three- or six-month notice periods — some offer month-to-month terms. When the partnership ends, you should already have a new Responsible Person named before your current one steps down. Some providers also help with the transition and hand over your documentation. Recommendation: clarify these points before signing your contract, not when you're under time pressure.
Do I need a separate Responsible Person for each product, or can one cover everything?⌄
One Responsible Person can cover multiple products — that's actually the standard. A service provider can manage your entire product portfolio, not just specific categories. Some providers scale their fees based on portfolio size or how often technical documentation needs updating. A Responsible Person for ten simple products (e.g. various silicone kitchen utensil types) might cost €150 per year; for 200 complex products with frequent updates, closer to €500. That's market standard and should be clearly stated in your quote.
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