EU Responsible Person Requirements: Myths Busted for 2024

Introduction: Why 2024 Is a Crucial Year for EU Compliance

How the GPSR Update Alters Market Access in 2024

The updated General Product Safety Regulation (GPSR), which officially takes full effect in 2024, has transformed the compliance landscape for all non-EU manufacturers aiming to sell goods within the European Economic Area. These new rules place a sharper focus on the designation and verification of an EU Responsible Person. As such, businesses can no longer afford to be lax or vague when appointing their EURP. The EU Responsible Person Requirements have become increasingly stringent, requiring structured documentation, traceability protocols, and a legal presence capable of responding to safety inquiries, market surveillance demands, and consumer protection requests.

For businesses using third-party selling platforms such as Amazon and Shopify, failure to comply could lead to product delisting, border seizure, or even legal penalties. The days of viewing your EURP as a mere logistical formality are over. In 2024, the EURP acts as your proxy for compliance accountability. Understanding the EU Responsible Person Requirements is vital to maintaining uninterrupted access to the EU marketplace and avoiding costly enforcement actions.

Myth 1: Any EU-Based Contact Can Be the Responsible Person

Clarifying Legal Requirements for the EURP Under GPSR

One of the most persistent misconceptions floating around within the e-commerce and manufacturing sectors is that any point of contact residing or registered within the EU can legally serve as the EU Responsible Person (EURP). This could not be further from the truth. The GPSR—specifically Article 4—explicitly outlines that the EURP must be a tangible legal entity with the capacity to fulfil regulatory duties on behalf of the non-EU manufacturer. This includes, but is not limited to, maintaining documentation, cooperating with market surveillance authorities and handling product recalls if necessary.

In other words, your friend living in Berlin or your virtual assistant’s limited liability company in Prague does not qualify unless they are contractually designated and adequately prepared to absorb all relevant legal risk. The EU Responsible Person Requirements specify that the EURP must be able to represent the foreign brand, respond in local languages, and provide immediate access to the technical documentation related to your product. This is not a passive role—it is a compliance-critical designation demanding rigorous oversight and formal acknowledgment in product labelling.

“The Responsible Person must be empowered and competent—not just available.” – EU Product Safety Authority, 2024

Myth 2: GPSR Doesn’t Apply to My Products

Too often, companies assume that the General Product Safety Regulation only impacts children’s toys or electronics. This myth stems from oversimplification and a lack of awareness about the broad spectrum of products subject to safety and traceability obligations. The GPSR applies to essentially all consumer products marketed within the EU that are not already covered by a specific sectoral regulation, such as medical devices or automotive components.

Products ranging from furniture and kitchen gadgets to beauty tools and hobby equipment all fall under the GPSR framework. If the item could potentially impact consumer health or safety, then your product must comply with the requirements. This includes labelling, secure traceability, and—most pertinently—nominating an appropriate EU Responsible Person. Every organisation seeking to operate legally from outside the EU needs to review the full regulatory text and ensure alignment based on their specific product segment.

Myth 3: Amazon Automatically Provides Compliance

Another prevalent fallacy is that platforms like Amazon or eBay automatically handle GPSR compliance, including the appointment of an EU Responsible Person. While Amazon has enhanced its product compliance checks post-GPSR, it is important to realise that responsibility ultimately falls on the brand owner or manufacturer. Amazon may alert sellers to gaps in documentation; it will not assume liability nor act as an EURP on behalf of third-party merchants.

As a result, your listing could be removed if you do not submit appropriate evidence that an EU Responsible Person has been designated. Shopify operates under similar constraints. Neither platform assumes legal obligation under the EU’s consumer protection frameworks unless they are directly involved in the product’s design, labelling, or safety management. The requirement to assign a compliant EURP is unavoidable and rests solely with the product’s originating company.

To ensure compliance, platform sellers must consider accredited service providers or subsidiaries with demonstrable legal capacity to operate as an EURP. You can learn more about official third-party EURP services via Learn more about EU Product Compliance & Market Access.

Key GPSR Milestones Every Brand Must Know

The remodelling of the General Product Safety Regulation has been several years in the making, culminating in its full enforcement during 2024. Below are some mandatory compliance checkpoints brands should be aware of:

• July 2021: Proposal of revised GPSR alongside public consultations
• May 2023: Official ratification of the updated regulation by EU Parliament
• December 2023: Soft enforcement begins, with letters sent by market surveillance bodies
• June 2024: Full enforcement commences, with mandatory EURP assignment, product labelling, and traceability compliance checks conducted at EU borders

Each milestone serves as a reminder of the deliberate, detailed path the EU has taken to enhance consumer safety. At every juncture, the presence and competence of your EURP becomes a legally binding prerequisite.

Who Qualifies as an EU Responsible Person in 2024?

To qualify as an EU Responsible Person under the 2024 GPSR guidelines, a party must:

• Be officially established within the European Union or EEA (European Economic Area)
• Have the clear written mandate from the manufacturer to represent them in all safety and compliance matters
• Be authorised to store and submit the product’s technical documentation to competent authorities
• Respond to consumer and regulatory questions in the official language(s) of the country in which the product is marketed

The EU Responsible Person Requirements are exacting by design. EU lawmakers expect this representative to function as a local extension of the external manufacturer. Consequently, appointment involves strategic trust, operational alignment, and legal clarity.

Why Shopify & Amazon Sellers Must Pay Closer Attention

E-commerce sellers on platforms like Shopify and Amazon often overlook their regulatory responsibilities, assuming that online marketplaces alleviate their legal burden. However, according to the updated GPSR rules, non-compliance is not just a matter of violating platform policy—it’s a legal offence.

If your product is discovered without proper labelling, risk assessments, or a named EURP, it can be detained at customs or outright banned from sale within EU member states. This has already occurred in 2024 in several instances involving beauty tools and consumer tech accessories, where barcode mismatches flagged missing EURP designations.

Understanding and fulfilling EU Responsible Person Requirements provides competitive resilience, aligning not just with regulation but also with consumer expectations around transparency and safety. 2024 GPSR regulation changes and deadlines

Appointing a Trusted EU Responsible Person: Step-by-Step

Choosing a compliant and competent EURP in 2024 requires more than just signing a contract. Follow these steps to ensure full alignment with all legal responsibilities:

1. Pre-select a qualified entity—must be an EU-based business with operational capability.
2. Draft a comprehensive mandate outlining responsibilities, communication frameworks, and indemnity concerns.
3. Provide full technical documentation for each product, including labelling, Declaration of Conformity (DoC), and risk assessments.
4. Notify internal teams working on packaging and marketing to include EURP name and address properly per Article 4 requirements.
5. Quickly respond to any enforcement queries through direct access to your EURP contact.

This structured approach underscores your commitment to legality and helps build longevity in the EU marketplace. For further advice on maintaining compliance across regulatory cycles, visit Read a related article.

Top Mistakes Brands Make with EU Product Safety

Even seasoned manufacturers make avoidable errors during GPSR implementation. The most frequent issues include:

• Appointing third-party logistics providers (3PLs) as EURPs—this often breaches legal expectations unless the 3PL explicitly agrees.
• Assuming translation is optional—labelling must appear in the language(s) of the country of sale.
• Neglecting document maintenance—technical files must be updated and accessible for up to 10 years post-product lifecycle.
• Using outdated CE declarations—some brands mistakenly reuse EU DoCs without adapting them to the correct regulation references.

Avoiding these mistakes is far easier and more cost-effective than dealing with retrospective compliance fines or legal disputes.

Conclusion: Make Compliance Your Competitive Advantage

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In 2024, navigating the EU Responsible Person Requirements is no longer just about avoiding penalties—it’s about winning consumer trust and securing market access. The GPSR has raised the compliance bar and offered forward-thinking brands an opportunity to stand out through proactive safety management and clear accountability. Appointing a qualified, cooperative, and fully authorised EURP is an investment in both legal security and market reputation. Let smart compliance define your market leadership.

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