Comparison of Responsible Person Product Safety Providers for Non-UK Sellers on Amazon and eBay

• Since July 16, 2021, an EU Responsible Person is required to sell CE-marked products on Amazon/eBay
• Prices and services vary: check what is included and coverage
• Non-compliance leads to product removal and fines up to 10 million euros
• Some providers offer designation only, others also provide document support
• Watch out for extra costs and exclusions (e.g., liability limits, per-product, per-request)
• Choice depends on non-EU country, sales channel, and product type

Updated 23 October 2026 · 12 sources checked

Providers compared

Prices as published on each provider's website on 23 October 2026, excluding VAT unless stated. Each row links to its source.

Legal Requirements: Articles and Obligations

The General Product Safety Regulation (GPSR) (EU 2023/988) mandates that all consumer products sold in the European Union, including those marketed via marketplaces like Amazon and eBay, must comply with EU safety standards. Article 16 of the GPSR requires each product to have a Responsible Person established in the Union, acting as a contact point for authorities and consumers and retaining technical documentation for at least ten years.

Since July 16, 2021, the Market Surveillance Regulation also requires CE-marked products to have an EU Responsible Person, as confirmed by Amazon's compliance policies (source). eBay, via its regulatory support page (source), allows sellers to compare providers and requires Responsible Person information clearly displayed in listings.

• The Responsible Person must be appointed in writing and their details (name, address) must appear on labels, packaging, and where required, in marketplace fields.
• Failure to appoint leads to listing removals and severe administrative fines, up to 10 million euros or 2% of global turnover (Art. 83(4)(a) GDPR for personal data, with similar GPSR penalties).
• Responsibility covers not only the listing of the name but also retention of technical documentation and handling authority and consumer requests.

Additionally, sellers also operating in Switzerland must verify if all conditions of Art. 14 nFADP (nLPD/nDSG) apply: REP27 offers a free evaluation with every plan to determine if a Swiss representative is also required.

How to Choose the Right Provider: Practical Criteria and Decision

Choosing a Responsible Person provider depends on several practical factors:

• Country of establishment: non-EU sellers (USA, UK post-Brexit, China, Turkey, etc.) must appoint an EU Responsible Person to sell to consumers in the Union.
• Number of products/families: some providers limit coverage per product or family, others (like REP27) cover unlimited catalogs.
• Sales channel: marketplaces (Amazon, eBay, TikTok Shop) require designation at onboarding; for own stores (Shopify, WooCommerce), obligation arises after customs checks, complaints, or audits.
• Need for additional services: some providers offer designation only, others also GDPR support, request desks, multilingual documentation, and responsible person changes at no extra cost.
• Budget and payment method: annual plans, one-time fees, modular or subscription options exist.

Decision table:

Before choosing, always verify if the provider covers your entire catalog, offers support for authority requests, and if the designation is publicly verifiable. Also consider issuance speed and clarity of contract terms.

What’s Really Included in the Price: Detailed Comparison

Not all providers offer the same service level; differences can be substantial in coverage and support. Here is a comparison table based on published data:

Comparing services, REP27 offers designation for unlimited catalogs, multilingual documentation, request desk, and responsible person change included, while others may limit product numbers or exclude support services. EUSellKit, for example, provides monitoring and document archiving but not legal designation. Before choosing, carefully check what is included and if there are extra fees for requests, new products, or responsible person changes.

Hidden Costs and Limits: What to Ask Before Signing

Many providers publish base prices covering only part of a seller’s real needs. Key points to verify:

• Product/family limits: some plans cover only 1-5 products or families, with extra fees for each new addition.
• Costs for authority or consumer requests: some providers charge fees per handled request or for producing technical documentation.
• Liability exclusions: provider’s legal liability may be limited contractually, leaving the seller exposed in disputes.
• Notice for provider change: switching providers may cause coverage gaps if not managed properly (REP27 advises signing the new mandate before ending the previous one).
• Validity of designation: check that designation is publicly verifiable and certificate updated in real time (REP27 offers QR code and public verification page).

Questions to ask before signing:

• How many products/families does the plan cover?
• Are there extra fees for authority requests or each new product?
• How does responsible person change work and what are the timelines?
• Is the designation publicly verifiable?
• What liability does the provider assume in case of disputes?

How Appointment Works: Step by Step and Practical Tips

1. Analyze your catalog and sales channels: check if you sell GPSR-subject products and if you operate via marketplaces or own stores.
2. Choose the most suitable provider and plan: consider coverage, included services, limits, and issuance speed.
3. Sign the designation mandate: most providers offer digital signing; REP27 issues designation within 24 hours of payment.
4. Receive documentation: get signed letter/certificate, label and packaging details, and instructions to update marketplace listings.
5. Update data in marketplaces: enter the Responsible Person in required fields (e.g., Amazon Seller Central, TikTok Shop Seller Centre).
6. Apply changes to labels and packaging: update data on new production; for already printed stock, over-labeling is generally accepted.
7. Keep technical documentation: retain declaration of conformity and technical file for at least 10 years.
8. Manage requests: ensure provider has a desk forwarding authority and consumer requests promptly (REP27 guarantees forwarding within 2 working days).
9. If changing provider: sign the new mandate first, update data immediately, then terminate the previous one to avoid coverage gaps.

Practical tip: plan label and packaging changes before next production to avoid reprint costs or corrective labels on already shipped stock.

Risks and Penalties: What Happens If You’re Not Compliant

Failing to appoint an EU Responsible Person or having a non-compliant designation carries real risks and severe penalties:

• Immediate listing removal: Amazon, eBay, and other marketplaces may suspend or delete offers upon detecting absence or irregularity of designation.
• Customs blocks and product seizures: customs authorities can hold products lacking an EU Responsible Person or with outdated data.
• Documentation requests: EU authorities may request declaration of conformity and technical file anytime; failure to respond or incomplete documentation exposes you to fines.
• Administrative fines: penalties can reach up to 10 million euros or 2% of annual global turnover (for GDPR, with similar severity for GPSR).
• Civil and criminal liability: in case of incidents or unsafe products, the Responsible Person may be held accountable alongside the manufacturer.

Authorities may also publish public alerts (Safety Gate) damaging seller reputation. The designation is not just a formality but a real safeguard for business security and consumer protection.

What Providers Usually Don’t Say: Limits, Exclusions, and Warnings

• Coverage limits: many services cover only a few products or families; REP27 offers unlimited coverage, others require upgrades or extra fees per new addition.
• Extra costs for requests: some providers charge fees for each authority or consumer request or for producing technical documentation.
• Limited liability: provider’s legal responsibility may be reduced via contract clauses; always check what happens in case of disputes or incidents.
• Notice and timing for changes: changing providers can cause coverage gaps if the new mandate isn’t signed first (REP27 always recommends overlapping designations).
• Non-verifiable designation: some providers don’t offer a public register or verifiable certificate; this can cause problems during inspections.
• Designation alone is not enough: product technical and documentary compliance remains the seller’s responsibility; the Responsible Person is only a contact point and doesn’t exempt other legal obligations.

Before signing, always request a sample certificate, service terms, and procedures for authority requests or provider changes.

Practical Scenarios and Simplest Path: Concrete Examples

• USA SaaS seller: If you offer only digital services (SaaS), no GPSR Responsible Person is needed. However, if you collect personal data of EU citizens, a GDPR representative may be required (see other specific guides on this site).
• China Amazon seller: To sell physical products to EU consumers, an EU Responsible Person is required for each product. Choose a provider covering your entire catalog and issuing designation quickly. Update Amazon data and labels immediately. REP27 offers designation in 24 hours and unlimited coverage.
• UK online shop post-Brexit: If you sell in the EU, you must appoint an EU Responsible Person. For Switzerland, check if all conditions of Art. 14 nFADP apply: REP27 includes a free evaluation with every plan and issues an exemption declaration if conditions are not met.

In all cases, the simplest path is:

1. Check if your product is subject to GPSR
2. Choose a provider with suitable coverage
3. Sign the mandate and update labels and listings immediately
4. Keep technical documentation and be ready to respond promptly to authority and customer requests

Checklist to Become Compliant Immediately: Concrete Actions

1. Check if you sell GPSR-subject products (consumer products, not just B2B)
2. Identify who the manufacturer is according to GPSR (see role table on REP27 pages)
3. Choose a provider covering your catalog and channels
4. Sign the mandate and receive documentation
5. Update labels, packaging, and marketplace listings with Responsible Person data
6. Keep declarations and technical files for 10 years
7. Prepare a compliance page accessible to EU customers
8. Verify presence of a request desk for authorities and consumers
9. If changing responsible person, sign new mandate first and update data immediately
10. Periodically monitor regulations and marketplace updates

Following these steps reduces risks of blocks, fines, and disputes, ensuring ongoing business compliance.