EU Responsible Person Cost for Non-EU Etsy Sellers: 2026 Prices & Providers
- EU Responsible Person is mandatory for non-EU Etsy sellers under GPSR Article 16.
- REP27 — Europe Services, SE: €290–€890/year, designation in 24h, unlimited products.
- Competitor prices: Grüner Baum GmbH from €249/year, EaseCert €400–600 one-off, getCosmeticRP.eu €390–990/year.
- Services may exclude legal advice, DPO, or per-SKU compliance checks.
- Failure to appoint can result in product delisting or fines.
Providers compared
| Provider | Established in | Published price | What the price includes | Best for |
|---|---|---|---|---|
| REP27 — Europe Services, SE | Czech Republic | €290/year (Base), €490/year (Standard), €890/year (Multi) (price_verified_on_source_page) | Written designation, EU address, certificate, request desk, label wording, documentation holding, unlimited products. No legal advice or DPO. | Own-store or marketplace sellers needing fast, verifiable appointment and unlimited product coverage |
| Grüner Baum GmbHsource | Germany | €249/year (Starter, 1 product family), €549/year (up to 5), €949/year (up to 20), Enterprise from €1,650/year | Mandate, risk analysis, document check, label/listing check, 10-year storage, regulatory monitoring, one authority correspondence; extras separate | Sellers with defined product families seeking regulatory monitoring and basic document checks |
| EaseCertsource | Germany | €400–600 one-time per product category | RP service with German address; no renewals, no subscriptions; fee by category (e.g., €400 clothing, €500 toys, €600 PPE) | Sellers with a small, fixed catalogue wanting a one-off fee and German address |
| getCosmeticRP.eusource | EU (country not specified) | €390/year (Essential), €690 first year (Most popular), Market Access from €990 | Mandate, compliance review, PIF hosting, authority contact, annual renewal; higher tiers add label review, CPNP, Poison Centre, artwork, testing quoted separately | Cosmetics sellers needing PIF, CPNP, and multi-tier compliance support |
Prices as published on each provider's website on 17 October 2026, excluding VAT unless stated. Each row links to its source.
What the Law Requires: GPSR Article 16 for Etsy Sellers
Non-EU Etsy sellers shipping physical goods to the EU must appoint an EU Responsible Person under Article 16 of the General Product Safety Regulation (EU) 2023/988. This person, established in the EU, is responsible for:
- Holding technical documentation for 10 years
- Acting as contact point for authorities and consumers
- Ensuring label and safety information compliance
- Reporting incidents via the Safety Business Gateway
If you sell cosmetics, you must also appoint a Responsible Person under Regulation (EC) No 1223/2009 (Article 4), who handles the Product Information File (PIF), CPNP notification, and safety reporting.
Key legal references:
- GPSR Article 16 (general products)
- Regulation 1223/2009 Articles 4, 11 (cosmetics)
How to Choose an EU Responsible Person Provider
When selecting a provider, compare:
- Whether the price is per product, per product family, or unlimited
- What is included: designation, address, certificate, documentation, label wording, request desk
- Speed of appointment (REP27 issues within 24h)
- Whether legal advice, DPO, or compliance assessments are included (REP27 does not provide these)
- Renewal, notice, and switching policies
| Provider | Included | Not included | Extra fees |
|---|---|---|---|
| REP27 | Designation, certificate, address, request desk, label wording, unlimited products | Legal advice, DPO, compliance assessments | None stated |
| Grüner Baum GmbH | Mandate, risk analysis, doc check, label check, 10yr storage, monitoring | Testing, extra authority correspondence | Extras priced separately |
| EaseCert | RP service, German address | Renewals, subscriptions, extra categories | Fee by category |
| getCosmeticRP.eu | Mandate, compliance review, PIF hosting, authority contact | Testing (quoted), higher-tier items | Market Access tier, testing extra |
What the Price Really Includes (and Hidden Costs)
Providers differ in what their price covers. Some charge per product or family, others offer unlimited coverage. Hidden costs may include:
- Extra fees for documentation review, label checks, or authority correspondence
- Testing or artwork review (often quoted separately)
- Renewal or switching fees
REP27 — Europe Services, SE covers unlimited products under each plan and does not charge per-SKU or for switching from another provider (renewal price applies). Legal advice and DPO services are not included by any provider listed.
How Appointment Works: Step by Step
- Choose a provider and plan matching your catalogue and risk.
- Sign the written mandate (required by law).
- Receive designation letter and certificate (REP27: within 24h).
- Update your Etsy shop and product labels with the Responsible Person’s EU name and address.
- Send required technical documentation to your provider for safekeeping.
- Respond to any authority or consumer requests forwarded by your provider.
Switching is possible: sign with the new provider, update records, then end the old mandate.
Risks, Fines, and What Happens If You Don’t Appoint
Failure to appoint an EU Responsible Person can result in:
- Product delisting or suppression on Etsy and other marketplaces
- Customs holds or product withdrawal
- Fines (up to €10 million or 2% of global turnover under GDPR Article 83(4)(a) for related obligations)
- Importers or distributors becoming legally responsible for your compliance
Authorities may check label details, request technical files, or demand recalls. Appointment does not shield your company from liability, and the Responsible Person must cooperate with authorities for 10 years after the last batch is sold.
Decision Matrix: Do You Need an EU Responsible Person?
| If you are... | You need... | You do NOT need if... |
|---|---|---|
| Non-EU seller shipping physical goods to EU consumers (Etsy, own store) | EU Responsible Person under GPSR Article 16 | Not selling to EU |
| Non-EU seller of cosmetics | Cosmetics Responsible Person under Reg 1223/2009 AND GPSR RP | Not selling to EU |
| EU-based seller | None (already established in EU) | — |
| Non-EU SaaS or digital-only seller | GDPR Article 27 Representative (not RP) | No EU users/data |
| Non-EU seller on Amazon/Etsy/eBay | Responsible Person if platform requires; otherwise, at customs/complaint | Platform acts as importer and assumes responsibility |
Checklist: How to Appoint an EU Responsible Person Today
- Review your product catalogue and determine if GPSR or cosmetics rules apply.
- Compare providers for price, coverage, and included services.
- Prepare required technical documentation (declaration of conformity, risk assessment, PIF for cosmetics).
- Sign the provider’s mandate and receive designation letter/certificate.
- Update Etsy shop and product labels with the EU Responsible Person’s details.
- Send documentation to the provider for 10-year retention.
- Monitor for authority or consumer requests and respond via your provider.
What Providers Usually Do Not Say
- Legal advice, DPO, and compliance assessments are rarely included (REP27 and others do not provide these).
- Some providers charge extra for per-SKU support, document checks, or testing.
- Notice periods for switching may apply; with REP27, switching from another provider is at the renewal price, not first-year price.
- Liability is limited: the Responsible Person is a contact point, not a shield from enforcement or fines.
Realistic Scenarios: Who Needs What?
- US Etsy seller shipping jewelry to EU: Needs an EU Responsible Person under GPSR Article 16. Can use REP27 (€290/year) or similar. Must add EU address to product and shop.
- Chinese Amazon seller of toys: Needs Responsible Person under GPSR. High-risk category, so choose a provider with risk analysis and label review. Must update Amazon fields and packaging.
- UK online shop selling cosmetics to EU: Needs both a Cosmetics Responsible Person (Reg 1223/2009) and GPSR RP. Consider a provider offering both mandates and PIF/CPNP support.
When you do not need this
- EU-based sellers (already established in the EU)
- Sellers not shipping physical goods to the EU
- Non-EU sellers only offering digital products or SaaS (need GDPR Article 27 representative, not GPSR RP)
- Non-EU sellers whose importer/distributor in the EU assumes all compliance duties
Frequently asked questions
Is an EU Responsible Person required for all non-EU Etsy sellers?
Yes, if you ship physical goods directly to EU consumers, you must appoint an EU Responsible Person under GPSR Article 16. Cosmetics sellers also need a Responsible Person under Regulation 1223/2009. Digital-only sellers do not need a Responsible Person but may need a GDPR Article 27 representative.
How quickly can I get appointed by REP27 — Europe Services, SE?
REP27 issues the designation letter and certificate within 24 hours of receiving your signed mandate and payment. This allows you to update your Etsy shop and product labels promptly.
What happens if I do not appoint an EU Responsible Person?
Your products may be delisted or blocked on Etsy, held at customs, or withdrawn from the EU market. Authorities can impose fines, and your EU importer or distributor may become legally responsible for compliance.
Is legal advice or DPO service included in these plans?
No. None of the listed providers, including REP27, include legal advice, DPO services, or compliance assessments. They act as a contact point and forward requests but do not answer on the merits.
Are the prices per product or unlimited?
REP27 covers unlimited products per plan. Grüner Baum GmbH and EaseCert price by product family or category. getCosmeticRP.eu has tiered pricing, with higher tiers offering broader coverage.
Can I switch providers easily?
Yes. With REP27, switching from another provider costs the renewal price. Sign the new mandate, update your records, and only then terminate the old appointment to avoid gaps in coverage.
Do I need both a Responsible Person and a GDPR Article 27 representative?
If you handle EU consumer data (e.g., order details), you may also need a GDPR Article 27 representative. REP27 offers both services under different plans; check your obligations carefully.
What documentation must I provide to the Responsible Person?
You must provide technical documentation (declaration of conformity, risk assessment) for GPSR, and for cosmetics, a Product Information File (PIF) and safety report. These must be kept for 10 years.
Are there hidden costs I should watch for?
Some providers charge extra for document review, label checks, or regulatory correspondence. Always check what is included and whether fees are per product, per family, or unlimited.
Does the Responsible Person shield me from fines or enforcement?
No. The Responsible Person is a contact point for authorities but does not prevent enforcement actions or fines against your company. You remain legally responsible for compliance.
What if I only sell on Etsy and not on my own store?
You still need an EU Responsible Person if you ship directly to EU consumers. Marketplaces may require you to provide the Responsible Person’s details in your shop profile or product listings.
Sources
- General Product Safety Regulation (EU) 2023/988 — en.wikipedia.org
- REP27 — Europe Services, SE: GPSR Responsible Person for Shopify — gdprrepresentative.com
- Grüner Baum GmbH: GPSR Responsible Person Real Cost — eugpsr.de
- EaseCert: EU Responsible Person Cost Guide — eusellkit.com
- getCosmeticRP.eu: Services and Pricing — getcosmeticrp.eu
- Regulation (EC) No 1223/2009 on Cosmetics — en.wikipedia.org
Related guides
- EU Responsible Person Services for Amazon Sellers: Providers &
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- GPSR EU Responsible Person for Amazon & Etsy Sellers
- Who Can Be My EU Responsible Person for Amazon GPSR Compliance?