How to Switch Responsible Person Without a Gap

To switch Responsible Person without a gap, appoint Eldris before your current appointment ends: the certificate follows within 60 minutes of completing onboarding. Eldris's position is that evidence of the new appointment covers stock already on the market with the old address, and stickers are the worst case. New packaging and online listings then carry Eldris's details, under Articles 16(3) and 19(b) of Regulation (EU) 2023/988, the GPSR.

When should you switch Responsible Person?

Switch before the old appointment ends, so the two overlap rather than leave a gap. The appointment with Eldris takes effect on completing onboarding. The certificate follows within 60 minutes of completing onboarding.

Article 16(1) of the GPSR is the reason. You may not place a product it covers on the EU market unless an economic operator established in the EU is responsible for it.

The placing on the market is the first making available of a product on the EU market, under Article 3(7). So any unit first made available during a gap would go on the market without one.

For toys, radio equipment and other products in Article 4(5) of Regulation (EU) 2019/1020, its Article 4(1) requires an EU operator in the same way.

Appointment with Eldris is online, in one form. The certificate names every market chosen, with a document reference number and the appointment date. So the start of the new appointment is on record.

Compare that date with the end date your old provider gives you. If the certificate's date comes before the old appointment ends, the two overlap.

What happens to old stock when you switch Responsible Person?

Eldris's position is that evidence of the new appointment covers stock already on the market with the old Responsible Person's address. Relabelling with stickers is the worst case, not the starting point. That position is Eldris's, not a rule quoted from the GPSR.

Eldris's certificate of appointment is that evidence. It names every market you chose, with a document reference number and the appointment date. It is ready to upload to any marketplace that asks for the Responsible Person.

When you switch Responsible Person, keep it in your records next to the date your old appointment ended. Add the old provider's written confirmation of that date.

Where you still need to relabel, the law gives a choice of place. Article 16(3) of the GPSR puts the Responsible Person's details on the product, its packaging, the parcel or an accompanying document. Article 4(4) of Regulation (EU) 2019/1020 gives the same choice for the products it covers, such as toys.

A sticker should cover only the old Responsible Person's details, never yours. Article 9(6) keeps your own name and address on the product as manufacturer.

What changes on new packaging and listings?

New packaging and every online listing carry Eldris's details. For EU markets they are EldrisAi OÜ, Ruunaoja tn 3, 11415 Tallinn, Estonia, with the email compliance@eldris.ai. The address appears on packaging, in Amazon Seller Central compliance fields and on marketplace listings while your monthly plan runs.

You may print packaging before the appointment, as long as it carries Eldris's name, address and email. So a print run need not wait for the day you switch Responsible Person.

Article 16(3) asks for a postal and an electronic address, which is why the email goes on with the address. Article 19(b) puts the same details in the online offer where the manufacturer is outside the EU.

Marketplaces must let traders give these details for each product, under Article 22(9). Cosmetics have their own label rule. Article 19(1)(a) of Regulation (EC) No 1223/2009 puts the Responsible Person's name and address on the container and packaging.

The guides to the name and address on your label and to when to print Eldris's details go further. Amazon sellers can also read the EU Responsible Person guide for Amazon sellers.

What should you settle before you switch Responsible Person?

Ask your current provider, in writing, for the date its appointment ends. Ask too what its terms ask you to do with its details. Then complete Eldris's onboarding before that date.

Each provider sets its own exit terms. So read yours for the notice period and any deadline for removing its details. Confirm which markets the old appointment covered, so the new one names the same ones.

Check whether any authority correspondence about your products is still open, and ask the old provider for copies. Eldris's terms ask you to notify it promptly of regulatory inquiries. So pass on anything still open once Eldris is your Responsible Person.

You do not need files from the old provider to sign up. You need no documents before payment. Afterwards you supply product information, including safety documentation, through the portal.

Your Declarations of Conformity and technical files stay with you or your test laboratory. If you ever move on from Eldris, the guide to cancelling the service sets out the exit.

How do you switch Responsible Person to Eldris?

The switch is the normal Eldris sign-up, done before your old appointment ends. The live flow runs through your details, then markets, what you sell and your plan. Then come the quote and the authorise step, with payment last.

1. Choose your markets. Pick the markets your old Responsible Person covered. Each EU member state and the UK is one market. There is a one-off fee for each market and a multi-market discount on those fees.
2. Pick your plan. Monthly plans go by SKU count. One plan covers all your markets, and one registration per market covers every product type.
3. Check the quote. You see it before any payment, and you can have it emailed as a full quotation (PDF).
4. Authorise. Confirm you have the right to appoint Eldris for the markets chosen and accept the terms. Then pay.
5. Receive the certificate. It follows within 60 minutes of completing onboarding. Update your listings, then end the old appointment.

The fees are on the service page pricing section. To switch Responsible Person, start at onboarding; the guide to appointing Eldris walks through each screen. The short answer is also in the FAQ on switching.

Frequently asked questions

Should I end my old appointment before I switch Responsible Person?

No, keep it until Eldris's certificate of appointment is in your hands. A product the GPSR covers may not go on the EU market unless an EU-established operator is responsible for it, under Article 16(1). So the safe order is the new appointment first and the old one ended second.

Does old stock need relabelling when I switch Responsible Person?

Not as a starting point, in Eldris's own position. Evidence of the new appointment covers stock already on the market with the old Responsible Person's details. Stickers with Eldris's details over the old ones are the worst case, and that position is Eldris's own, not a rule quoted from the GPSR.

What should a sticker cover?

Only the old Responsible Person's details. Your own name and address as manufacturer stay on the product under Article 9(6) of the GPSR, so a sticker should leave them visible. Where you relabel, Article 16(3) lets the new details go on the product, its packaging, the parcel or an accompanying document.

How do I switch Responsible Person on a fixed date?

Complete Eldris's onboarding before the end date your old provider gives you. The appointment takes effect on completing onboarding, and the certificate follows within 60 minutes with the appointment date on it. So the new appointment is on record before the old one stops, and the two overlap rather than leave a gap.

Do I need files from my old provider to appoint Eldris?

No, you need no documents before payment to sign up with Eldris. Afterwards you supply accurate and complete product information, including descriptions and safety documentation, through the portal. Your Declarations of Conformity and technical files stay with you or your test laboratory, so nothing has to come from the old provider.

Can I switch Responsible Person for my UK appointment too?

Yes, Great Britain is a separate appointment, added to the same order at the same market fee and covered by the one monthly plan. You can choose it alongside the EU markets in the same order, or on its own. For Northern Ireland, note that it follows the EU rules.