What a Responsible Person Does: The Four Tasks in Practice

A Responsible Person is the business based in the EU that answers to the authorities for your product. Article 4(3) of Regulation (EU) 2019/1020 lists what a Responsible Person does: check the documents exist, answer requests, report risks and help with corrective action. Eldris also handles the authorities' correspondence for you.

What does Article 4(3) say a Responsible Person does?

Article 4(3) requires it to do four tasks, listed below. Under GPSR Article 16(1), a covered product may not be placed on the market without an EU operator for them. The tasks leave the duties set by the product's own law in place.

• The product's law may ask for an EU declaration of conformity and technical documentation. If so, check they have been drawn up. Keep the declaration for the authorities for the period that law requires. Make sure they can get the documentation on request.
• Answer a reasoned request from a market surveillance authority. Give all the information and documentation needed to show the product conforms. Use a language the authority can easily understand.
• Tell the market surveillance authorities when there is reason to believe a product presents a risk.
• Work with those authorities. That includes making sure the needed corrective action happens when a product does not comply.

The text sets no deadline for what the Responsible Person does here. Neither the reply nor the risk report has one.

Cosmetics have a parallel rule in Article 5(3) of Regulation (EC) No 1223/2009. There, the responsible person answers an authority's reasoned request. It gives the facts and documents that show specific aspects of the product conform.

What does the GPSR add to those tasks?

It adds regular checks to what the Responsible Person does. They apply where the product's risks call for them. Under GPSR Article 16(2), it checks that the product complies with its technical documentation.

On request, it gives the authorities documented evidence of those checks. The Responsible Person does these checks on top of the four tasks of Article 4(3). They leave the other operators' duties under Regulation (EU) 2023/988 in place.

So the manufacturer keeps its own duties. Under Article 9(1), it designs and makes the product to meet the general safety requirement. Under Article 9(2), it runs an internal risk analysis and draws up the technical documentation.

Article 16(3) puts the Responsible Person's name and postal and electronic address on the product. Its packaging, parcel or an accompanying document can carry them instead. Article 19(b) puts them in online offers where the manufacturer is outside the EU.

The label guide covers what to print. But Article 16 does not apply to products with their own EU product law. For the acts listed in Article 4(5), Article 4 of Regulation (EU) 2019/1020 sets what the Responsible Person does instead.

The 2026 requirements guide covers who needs one and when.

What does Eldris do day to day?

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

For EU markets, your labels and listings carry EldrisAi OÜ, Ruunaoja tn 3, 11415 Tallinn, Estonia. The email is compliance@eldris.ai. Eldris also deals with the market surveillance authorities.

Your records sit in a portal you can open at any time. They include certificates and logs of authority mail. The terms name Eldris as your EU Responsible Person for cosmetics and for general consumer products.

When an authority writes, the times below are Eldris's own promises. They are not legal deadlines.

Eldris receives and logs post to the EU address. It then tells you within 24 hours.

It answers a formal information request for you from the documents in your portal. The initial response comes within 10 working days.

Eldris also copies you on every message. It consults you before any substantive response.

See what happens when an authority contacts Eldris for the full sequence.

What does Eldris need from you?

Accurate product details, a way to reach you quickly, and prompt word of any incident. What a Responsible Person does for an authority depends on what you supply. Eldris answers from your portal.

Under the terms, you provide accurate and complete product information. That means descriptions, ingredients where they apply, and safety documents. After payment, it goes into your portal.

You also tell Eldris promptly about any safety incident, recall or question from a regulator. Eldris handles the replies, but some authority questions are yours to answer. So it needs to reach you quickly.

The terms also require you to make sure your products comply with all applicable EU product safety rules. You do that before you place them on the EU market.

Eldris does not prepare declarations of conformity or technical files. You or your test lab do.

Its terms limit its role to acting as your EU Responsible Person. It provides no legal, tax or product safety testing services.

A Responsible Person does not take over your duties as manufacturer. They stay with you, as the guide to liability sets out.

How do you put a Responsible Person in place?

Appoint one before you place the product on the EU market. With Eldris that is one online order. It covers your details, markets, product types and plan, then the quote, and then you authorise.

Article 16(1) of the GPSR bars a covered product from the market without an EU operator to do what a Responsible Person does. Placing on the market means the first making available of the product on the EU market.

An online offer counts too. Under Article 4 of the GPSR, it makes the product available once it targets consumers in the EU.

At onboarding you choose your markets, select what you sell and pick a plan. You see the quote. Then you confirm your authority to appoint Eldris and accept the terms.

The certificate comes within 60 minutes of completing onboarding. It names every market you chose. The one-off fee for each market and the monthly plan, priced by SKU count, are on the service page.

For each step, read how to appoint Eldris. The short answer is in the FAQ entry on the role.

Frequently asked questions

Does the Responsible Person have to be based in the EU?

Yes: Article 16(1) of the GPSR asks for an economic operator based in the EU. That can be an EU manufacturer, or an importer where the manufacturer is outside the EU. It can also be an authorised representative with a written mandate, or a fulfilment service provider only where none of those is in the EU.

How quickly does Eldris answer an authority?

Eldris receives and logs post to the EU address, then tells you within 24 hours. A formal information request gets an initial response within 10 working days, drawn from the documents held in your portal. Both are Eldris's own service promises, since Article 4(3)(b) sets no deadline for any reply.

Do the GPSR's regular checks apply to every product?

No: the Responsible Person does these checks where the product's possible risks call for them, and only for products the GPSR covers. Article 16 does not apply to products with their own EU product law. For the acts listed in Article 4(5) of Regulation (EU) 2019/1020, the four tasks still apply under its Article 4(1).

Who tells the authorities about a dangerous product?

The Responsible Person does, under Article 4(3)(c) of Regulation (EU) 2019/1020, which names no hour or day limit. It tells the market surveillance authorities when it has reason to believe a product presents a risk. Eldris's terms also have you tell Eldris promptly about any safety incident, recall or question from a regulator.

Is a Responsible Person the same as an importer?

Not always: an importer is a business based in the EU that places a product from a third country on the EU market. Article 4(2)(b) of Regulation (EU) 2019/1020 lets an importer hold the role. An authorised representative with a written mandate can hold it instead, as can an EU manufacturer.