EU Responsible Person Rules for UK Sellers in 2024

Understanding the Role of an EU Responsible Person

What the EU RP does for non-EU sellers

The EU Responsible Person Rules require that any business located outside of the European Union—which now includes the United Kingdom following Brexit—must appoint a designated agent or representative inside the EU to serve as their “Responsible Person.” This representative acts as the local legal entity that authorities can correspond with in the case of product safety inspections, market surveillance, or product-related consumer concerns.

An EU Responsible Person (EU RP) plays a pivotal regulatory role. Essentially, the RP ensures compliance with all relevant EU legislation such as the General Product Safety Regulation (GPSR), the Cosmetics Regulation (EC) No 1223/2009, and the Medical Device Regulation (EU) 2017/745, depending on the nature of the product. For many UK businesses that previously sold to EU countries without issue, this marks a fundamental shift.

The EU RP must hold a technical file or necessary documentation related to the product, provide it promptly upon request from authorities, and take corrective actions if a product fails to comply with safety requirements. More importantly, their name and address must be clearly visible on product labels or packaging so both market authorities and consumers can contact them if needed.

Legal Requirements Under the EU GPSR 2024

Impact on UK product sellers and platforms

As of July 2024, EU General Product Safety Regulation (GPSR) fully replaces the older General Product Safety Directive (GPSD). This updated regulation introduces specific obligations for e-commerce sellers and marketplaces targeting EU consumers. Crucially, foreign or UK-based businesses without a physical presence within the EU are now prohibited from placing consumer products on the EU market without first appointing an EU Responsible Person.

The GPSR also requires businesses and marketplaces to actively monitor product recalls, manage incident reporting, and ensure all safety data is localised and available in appropriate languages. Platforms like Amazon, Etsy, and Shopify are stepping up enforcement to remain compliant with the GPSR. If a seller fails to indicate their designated EU RP on a product placed on such marketplaces, their listings may be removed or suspended altogether.

Furthermore, manufacturers or sellers must ensure product traceability. This includes providing detailed records on who supplied products and where products were shipped. For non-EU businesses, an EU RP assumes responsibility for this traceability in direct collaboration with EU market authorities.

“Without a designated EU Responsible Person, your UK-based business cannot legally sell consumer products to EU customers under the new GPSR 2024 rules.”

Why UK Sellers Need an EU RP After Brexit

Brexit marks a clear regulatory divide between the UK and EU product compliance standards. Prior to the UK’s departure from the EU, UK sellers were treated as part of the Single Market and could sell freely across the bloc. Since 2021, UK sellers are now “third-country” entities, meaning they must appoint EU-based representatives to ensure that all products entering the European market meet the same authorised safety and compliance standards expected from any non-EU importer.

Without meeting the EU Responsible Person Rules, UK exporters risk product confiscation at the EU border, massive fines, and irreversible brand damage. Critically, customs checks are now more frequent, and businesses that fail to name and locate their RP are flagged for non-compliance. Appointing a compliant and trusted EU RP serves not only to meet legal obligations but also to enhance the credibility and trustworthiness of the UK-based seller in the eyes of EU distributors and consumers.

How to Designate Your EU Responsible Person

When appointing an EU RP, careful consideration must be given to both location and technical capability. The RP must reside within an EU country where you plan to trade. Many sellers opt for representatives in strategically central hubs like the Netherlands, Germany, or Ireland—regions with well-established logistics and a strong grasp of EU regulatory infrastructure.

To designate an EU RP, you’ll need to enter into a written mandate or service agreement explicitly outlining the EU Responsible Person’s responsibilities. This includes retaining technical files, cooperating with market authorities, and acting as the primary contact for safety queries. The RP’s physical address must be clearly marked on product labels—as per Article 4 of the GPSR—and this information must be visible before the product purchase is concluded online.

Third-party compliance service providers offer EU RP services, or an affiliate, distributor, or legal representative within the EU may be appointed. However, the selected entity must demonstrably possess the capabilities to perform duties outlined under EU law.

Top GPSR Compliance Tips for UK-Based E-commerce Businesses

To comply successfully with the EU Responsible Person Rules and broader GPSR obligations, UK sellers should follow a detailed and proactive compliance roadmap:

• Appoint a qualified EU Responsible Person with experience in your product category.
• Review your technical product documentation and ensure it meets EU standards.
• Include the RP’s details on all product labels prior to exporting.
• Ensure your EU RP keeps updated safety and incident logs.
• Regularly audit your compliance processes and labelling requirements.

By implementing rigorous internal protocols and communication channels with your designated EU RP, businesses can demonstrate preparedness and reduce intervention by regulatory bodies.

Consequences of Non-Compliance with EU RP Rules

Failure to comply with the EU Responsible Person Rules can have severe financial and reputational implications. EU member states are actively increasing market surveillance. Non-compliant shipments may be denied entry or seized by customs authorities. Moreover, online platforms could delist non-compliant product listings.

Manufacturers and exporters who do not indicate their EU RP visibly on the packaging risk being blacklisted by retail partners or banned from selling via third-party marketplaces. Even worse, in the event of a product safety incident, the absence of correct documentation can lead to legal prosecution or product liability claims.

Checklist for Selling Compliantly to the EU

Use this checklist to ensure you meet the primary obligations under the EU Responsible Person Rules:

• ✔ Appoint a verified EU RP with proven regulatory experience
• ✔ Draft and sign a mandate contract defining responsibilities
• ✔ Add EU RP name and address to product labels or packaging
• ✔ Maintain updated technical documentation across product lines
• ✔ Submit product data to market surveillance portals if required
• ✔ Conduct testing and audits to verify product safety and traceability

EU RP Services: What to Expect and How to Choose

When selecting an EU RP service, businesses should look beyond pricing and consider experience, industry knowledge, and response times. Top-tier EU RP providers offer dashboard portals for managing documentation, incident logs, and real-time regulatory updates.

Look for providers offering multilingual support, GDPR-compliant data handling, and transparent billing. Avoid companies who lack internal compliance personnel or cannot demonstrate prior representation with EU regulators.

The EU RP may also be audited themselves, so choosing a capable and credible representative is paramount for sustained EU market access. Consider asking peers and forums for referrals and reading reviews via trusted networks like Etsy Seller Handbook: Selling to EU Customers.

GPSR and Online Marketplaces: Etsy, Amazon, Shopify

Under the GPSR 2024, online platforms share regulatory responsibilities. Etsy has started issuing notifications to sellers demanding an EU Responsible Person be appointed before items are shipped to EU customers. Similarly, Amazon has rolled out strict labelling and compliance checks across its EU domains, and sellers found lacking representation have faced severe account consequences.

Shopify merchants are similarly at risk. While Shopify itself doesn’t enforce EU RP designation, it’s your responsibility to ensure labelling and documentation meet EU import requirements. Sellers operating across multiple platforms must centralise compliance operations, ideally through a single EU RP, to avoid redundancies or conflicting documentation.

Common Challenges for SMEs Navigating EU Compliance

Small to medium enterprises (SMEs) often struggle with meeting the full scope of the EU Responsible Person Rules. Lack of legal resources or internal compliance teams generally means that SMEs rely entirely on third-party providers. However, not all EU RP vendors are created equal, and distinguishing reputable representatives from undermanned operations can be difficult.

Another challenge is cost. SME owners may hesitate to invest in EU RP services, unaware that non-compliance risks far surpass initial service fees. Education and accessibility remain two key factors in overcoming compliance barriers. Learn more about EU Compliance and Responsible Person Regulations offers a beginner’s guide for UK SMEs entering EU markets.

FAQs on EU Responsible Person Rules for UK Exporters

Is an EU RP required for all product categories?

While all consumer products fall under GPSR, certain products such as cosmetics, medical devices, and electronics have their own directives that also require an EU RP. Always verify which regulations apply to your goods.

Can a warehouse be designated as an EU RP?

No. A logistics provider or warehouse cannot serve as an EU RP unless they have formally accepted the mandate and meet personnel and legal obligations. The RP must be empowered and competent to perform representation duties.

Where do I add the RP details on the packaging?

EU RP name, address, and contact details should be included on the retail packaging or, if not feasible, on the product label or accompanying documentation. This information must also appear on electronic listings before online checkout.

How often should I update product documentation?

Your EU RP must hold the most current technical file. This file should be reviewed with every product iteration or at least annually to reflect testing updates, changes in materials, or design alterations.

Final Thoughts: Stay Compliant and Grow with Confidence

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