Responsible Person and EPR: Two Different EU Duties

No: a Responsible Person and EPR registration are two different duties, and Eldris offers EPR as a separate service. Under Article 16 of the GPSR, the Responsible Person is the EU operator named on your product who answers the market surveillance authorities. Extended producer responsibility (EPR) is the duty to register with each country's producer register for packaging, electrical equipment and batteries, and pay for recycling.

How do a Responsible Person and EPR registration differ?

One is about safety, the other about recycling. A Responsible Person answers for your product's safety in the EU. But EPR is about who pays to recycle your packaging, WEEE and batteries, country by country.

Product safety law asks who in the EU an authority can turn to about a product. Under Article 16(1), you may not place a GPSR product on the market unless an operator established in the Union is responsible for it.

That operator carries the tasks in Article 4(3) of Regulation (EU) 2019/1020. Article 16(3) also requires its name and postal and email address. These go on the product, its packaging, the parcel or a document with it.

EPR asks who pays to recycle what you put on sale. So you register and pay for recycling in each country where you sell. Each country's register covers packaging, electrical waste (WEEE) and batteries.

The Responsible Person and EPR rules answer two different questions. So a seller can meet one duty in full and still owe the other. You may need both for one product.

What does the Responsible Person role cover?

It makes one operator established in the EU answer to the authorities for your product. Its tasks come from Article 4(3), which the GPSR applies.

Some product rules call for a declaration of conformity and technical documentation. If so, it checks that they exist.

It answers an authority's reasoned request. It also tells the authorities about a risk and works with them on corrective action.

Article 4(1) of Regulation (EU) 2019/1020 sets the same rule for some other goods. Toys and low-voltage electrical equipment are examples.

Cosmetics have a Responsible Person of their own, under Regulation (EC) No 1223/2009. The guide to what a Responsible Person does covers these tasks in practice.

None of those tasks mentions a producer register or recycling. Nor does Article 16 of the GPSR. Eldris holds the role through EldrisAi OÜ, for cosmetics and for general consumer goods.

While your monthly plan runs, Eldris's details go on your packaging and listings. They are EldrisAi OÜ, Ruunaoja tn 3, 11415 Tallinn, Estonia, and compliance@eldris.ai. Eldris also handles all your regulatory mail and deals with the authorities for you.

What does EPR registration cover?

Producer registration, one country at a time. Each country where you sell has its own producer register. Signing up there covers your packaging, WEEE and batteries.

That makes EPR a country-by-country task, unlike the safety role. In law, one Responsible Person established in the Union can act for you across the EU.

Eldris charges a one-off fee for each market you choose. Your certificate then names those markets.

But EPR works the other way. You sign up with the register of each country you sell in. So one more country means one more sign-up.

Eldris runs EPR as its own service on epr.eldris.ai. It signs you up with each country's register. The service also includes an authorised representative and the annual reporting.

That representative is part of the EPR service. But the safety role comes from the EU Responsible Person service. An authorised representative holds that role under Article 4(2)(c) only with the maker's written mandate.

EPR prices are on the EPR site, not in this guide.

How do the Responsible Person and EPR compare side by side?

Each service does its own job. The appointment gives you an EU operator for product safety. EPR puts you on each country's register for recycling.

Your monthly plan keeps your appointment active, with Eldris's address on your label and listings. It also covers replies to the authorities and the portal with your certificates.

None of that puts you on a producer register. Your certificate names the markets you appoint Eldris in, not EPR sign-ups. And Eldris's terms limit the role to acting as your EU Responsible Person.

How do you get a Responsible Person and EPR from Eldris?

Separately: Eldris offers each as its own service, with its own prices. A seller can need both a Responsible Person and EPR for the same product. One covers its safety, and the other its recycling.

For the appointment, start in the onboarding form and give your company details. Then choose your markets, the product types you sell and a plan by SKU count. One registration per market covers every product type you select.

You see your quote before you pay. The certificate then follows within 60 minutes of completing onboarding. The one-off fee for each market and the monthly plan are on the service page.

For EPR, start on the EPR site, where you sign up country by country. That site also shows the EPR prices.

Holding one does not stand in for the other. Eldris runs the Responsible Person and EPR services apart. So if you need both, you sign up for each.

The guide to one EU Responsible Person explains why the safety role needs only one EU operator. The Responsible Person FAQ keeps the short answer.

Frequently asked questions

Does my EPR registration include a Responsible Person?

Not by itself: a Responsible Person and EPR are two duties, not one. EPR puts you on each country's own register for your packaging, WEEE and batteries. But the Responsible Person under Article 16 of the GPSR is its own role, and at Eldris its own service, with its own prices.

Does an EU Responsible Person register my packaging?

No: the appointment keeps Eldris's address on your label and listings, and it covers replies to the authorities. It also gives you a portal that holds your certificates of appointment. But putting your packaging on a producer register is EPR, which Eldris offers as its own service on its EPR site.

Do I need a Responsible Person and EPR in each EU country?

Only EPR runs country by country: it is the duty to register and pay for recycling in every country where you sell. The Responsible Person works the other way. In law, one operator established in the EU can act for you across the Union, and Eldris names the markets you choose on your certificate.

Is the authorised representative in Eldris's EPR service my Responsible Person?

No: the Responsible Person and EPR roles come from different Eldris services. The authorised representative in the EPR service comes with your EPR sign-up and its annual reporting. But the safety role for your product under Article 16 of the GPSR comes from the EU Responsible Person service, held by EldrisAi OÜ.

Where are the EPR prices?

On epr.eldris.ai, the Eldris EPR site, where you sign up country by country. This guide prints no EPR price, and the Responsible Person and EPR prices sit on different pages. The one-off fee for each market and the monthly plan, priced by SKU count, are on the Eldris service page.

Who answers the authorities about my product's safety?

The Responsible Person: under Article 4(3) of Regulation (EU) 2019/1020, it answers an authority's reasoned request for information. It also tells the authorities about a risk and works with them on corrective action. With Eldris, you get a copy of all correspondence, and Eldris consults you before any substantive reply.