REP27 · Marketplaces · Amazon
Seller Central · Article 16 GPSR · Article 27 GDPR
Amazon uses the phrase authorised representative for the entity established in the Union that answers for your product. It enforces that one hard: the field is mandatory and the offer disappears without it. What Amazon never asks about is the personal data of your European buyers, which is governed by a different regulation with much larger fines. Sellers who have solved Seller Central usually still have the second gap open.
Seller CentralAmazon.deAmazon.frAmazon.itAmazon.esArticle 16Article 27
Step four is the one sellers skip and inspectors check. Seller Central holds a database record; the authority holds your parcel.
| Amazon says | The law says | Practical effect |
|---|---|---|
| Authorised representative | Economic operator: manufacturer, importer, authorised representative or fulfilment provider | Any of the four can be named, if established in the Union |
| Responsible person | Article 16 GPSR | Same thing, different label in the interface |
| Compliance dashboard | No legal status | A field check, not proof of compliance |
| Nothing about privacy | Article 27 GDPR | Your obligation, unprompted and unenforced by Amazon |
| Country dropdown | Establishment in a Member State | UK, Swiss and Norwegian addresses are refused |
You export buyer data, run email marketing, ship from your own systems, use a third-party tool with customer details, or sell from your own store as well.
You sell exclusively through Amazon, use Fulfilment by Amazon and never touch personal data outside the platform.
Whether you determine purposes and means for any processing of your own, not by how the marketplace describes itself.
Most sellers with a brand and a mailing list are controllers, and the designation costs less than a week of ad spend.
Europe Services, SE, Na Čečeličce 425/4, Praha 5, named in Seller Central and on the label, with a verifiable certificate.
Including the accented characters that break most listing tools, with a legal ASCII fallback.
So the physical product matches the marketplace record, which is what an inspector compares.
Declaration of conformity and technical file, available to authorities for ten years.
Article 27, with the privacy notice paragraph, on the same invoice and renewal date.
| Effect | Recovers automatically? |
|---|---|
| Buy box restored | Yes, usually within hours of valid details |
| Search rank on Amazon | No, rebuilt with sales velocity over weeks |
| Sponsored campaigns | No, budget spent pointing at a dead offer is gone |
| Account health | Repeated compliance blocks are treated as a pattern |
| Inventory ageing in FBA | No, storage fees continue while the offer is down |
Not the UK, not Switzerland, not Norway. The dropdown rejects the rest.
A brand name in that field is the most common rejection we see.
German on Amazon.de, French on Amazon.fr. English everywhere counts as no warning.
Type, batch or serial. Without it a recall takes the entire ASIN family.
Listing and packaging must name the same operator; divergence is what opens a file.
Three regulations reach a marketplace seller, and Amazon enforces two of them at different moments. Seeing all three next to each other is the fastest way to find what is missing.
| Obligation | Source | Where Amazon touches it | Consequence if absent |
|---|---|---|---|
| Trader verification | Article 30 DSA | Account onboarding | Cannot list at all |
| Responsible person | Article 16 GPSR | Manage Your Compliance | Offer suppressed |
| EU representative | Article 27 GDPR | Nowhere | Fines up to €10 million or 2% of turnover |
| Product conformity | Sector directives | Document requests on some categories | Goods refused entry or withdrawn |
Read the third row again. Amazon has no field for it, sends no reminder and will never suspend you over it. That silence is what makes it the most expensive of the four, because nothing external tells you it is missing until an authority does.
Your parcel is the first making available in the EU, so an EU-established operator must be named. This is the standard case.
Stock sitting in a fulfilment centre has not yet been supplied. The obligation bites at the first sale, not at the inbound shipment.
Then the importer places the goods on the market and carries the product obligations. The data question is decided separately.
Selling under your own brand makes you the manufacturer for EU purposes, whoever produced the item.
One designation covers every ASIN in the account; the technical documentation is per product.
Substantial modification makes the modifier the manufacturer for the modified aspects. Cleaning and testing does not.
Amazon shows one seller name, and the legal picture behind it varies. These four cases cover almost everything we are asked about.
| Case | Who is the manufacturer | Who is named as operator |
|---|---|---|
| Private label under your brand | You | An EU-established operator you appoint |
| Reselling a third-party brand imported by you | The brand owner | You as importer, or an appointed operator |
| Reselling goods bought from an EU distributor | The brand owner | The existing EU importer, already on the label |
| Bundling several products into a set | You, for the set | An operator for the bundle as placed on the market |
The third row is the only one where you may need nothing from us on the product side: the goods already carry a compliant EU operator, because someone else imported them. Check the packaging before buying a designation you do not need.
Amazon will stop you selling if the authorised representative field is empty, and will never mention the Article 27 representative even though the fines attached to it are far larger. Treat the first as a commercial emergency and the second as the one that actually needs a decision, because nothing external will ever prompt you about it.
Both are signed within 24 hours of one form. €290 a year for the product side, €890 for the plan that covers both, with two certificates carrying verification codes that Amazon, a buyer or an auditor can check without contacting you. The label wording comes with it, because Seller Central is a database record and the inspector is holding your box.
Yes. Europe Services, SE is a Czech company with a real registered seat, IČO 03571785, and Prague is a Member State address in the country dropdown.
The certificate carries a verification code on a public page. Support agents accept it because they can check it themselves.
Nothing changes. The designation covers the account, and new listings inherit the same operator details.
Only if the fields are emptied or the product falls under a category needing documents we do not hold. The designation itself does not lapse mid-year.
No, and no provider genuinely can. We give you the values and the certificate; the entry stays in your account.
The designation is not tied to any marketplace. It follows the product wherever you sell it in the Union.
Yes. Amazon uses both labels for the economic operator required by Article 16 GPSR, which must be established in the Union.
No. It is a marketplace, not an economic operator for your product, and it will not accept the role.
Yes. One EU-established operator covers Amazon.de, .fr, .it, .es, .nl, .se, .pl and .be. Only the warning language changes.
Since Brexit the United Kingdom is a third country for this purpose. The country field only accepts Member States.
The offer is suppressed: the ASIN stays but the buy box disappears and the item cannot be bought in the EU.
Usually within hours of valid details being saved. The lost search position is not restored automatically.
If you process buyer data outside Amazon, yes. A brand with a mailing list or its own store almost always does.
Not for Article 16. A fulfilment provider can be an economic operator, but Amazon does not accept that role for your goods.
Yes, when you sell as a business. Used, repaired and reconditioned products are covered.
Yes, in bulk. There is no per-ASIN fee on our side.
If your product falls under sector legislation, yes, and no representative can issue it. We hold the documentation, we do not test.
A different regime. An EU operator does not serve UK product rules.
No. A logistics provider that has not signed a mandate accepting the Article 16 tasks is not your operator.
Ten years from placing the product on the market. We hold a copy so a request does not depend on your supplier.
€290 a year for the responsible person, €890 for the plan that also covers the Article 27 representative.
A certificate with a verification code checkable on a public page, issued with the designation.
Related: what Amazon checks and what the law checks · the data side for Amazon sellers
The Article 16 operator Amazon requires and the Article 27 representative it never mentions, signed within 24 hours with certificates anyone can verify.
See the plans