EU Responsible Person under GPSR for Amazon Sellers: Providers & Prices (2026)
- GPSR Art. 16 requires Amazon sellers from non-EU countries to appoint an EU Responsible Person
- Obligation: Point of contact for authorities, retention of technical documentation (10 years)
- Missing information can lead to listing deactivation
- Prices: from €150 up to €890 per year (as of October 2026)
- Services, liability, and extra costs differ by provider
- Not every seller needs the service—see decision matrix
Providers compared
| Provider | Established in | Published price | What the price includes | Best for |
|---|---|---|---|---|
| REP27 — Europe Services, SE | Czech Republic | EUR 290–890/year (excl. VAT) | Appointment as Responsible Person, verifiable certificate, address for label, retention of technical documents, forwarding of inquiries, no legal advice | Amazon, TikTok, Shopify sellers from non-EU countries needing EU-wide coverage and fast issuance |
| GPSR-Guardsource | Germany | On request | Retention of technical documentation (10 years), point of contact for market surveillance authorities | Manufacturers focused on technical documentation and authority contact |
| GPSR Kitsource | United Kingdom | On request | Retention of technical documentation, point of contact for market surveillance authorities | UK-based companies exporting to the EU |
| Ax Holding Groupsource | United States | On request | Point of contact for market surveillance authorities, support with GPSR compliance | US companies with complex compliance needs |
| Responsible Person Findersource | United Kingdom | From €150 per year | Comparison of EU Responsible Persons, assistance with selection | Price-conscious beginners wanting to compare providers |
Prices as published on each provider's website on 15 October 2026, excluding VAT unless stated. Each row links to its source.
What does the law require? (GPSR Art. 16, 19, 22)
The EU Regulation 2023/988 (GPSR) introduces new, binding obligations from 2024 for manufacturers from non-EU countries selling physical products in the EU. Article 16 requires these manufacturers to appoint a Responsible Person based in the EU. This Responsible Person acts as a contact for market surveillance authorities, must retain technical documentation for at least 10 years, and is obliged to cooperate with authorities in case of safety issues (Source).
Under Article 19, the name and address of the Responsible Person must be indicated on the product, packaging, and every listing (e.g., on Amazon). This applies to all products covered by the GPSR, regardless of whether they are sold via marketplaces like Amazon, own online shops, or wholesale. Article 22 obliges marketplaces like Amazon to monitor GPSR compliance and deactivate listings in case of violations (e.g., missing information) (Source).
The Responsible Person is not just a formal contact but must also hold the complete technical documentation and respond to authority requests. The obligation applies to all manufacturers placing products on the EU market for the first time—whether selling directly to consumers (B2C) or to distributors (B2B).
If the appointment is missing or incomplete, Amazon may deactivate listings and authorities may impose measures up to fines. The rules also apply to white-label products and private labels as soon as the seller's name appears on the product.
How to choose the right provider? (Comparison & selection criteria)
Choosing the right Responsible Person is crucial for GPSR compliance and smooth selling on Amazon and other platforms. Key criteria include:
- EU presence: The Responsible Person must be based in the EU. Providers from third countries (e.g., UK post-Brexit, USA) cannot act in this role.
- Scope of services: Check if the provider not only appoints you but also retains technical documentation, forwards authority requests, and provides a verifiable address for product labeling.
- Certificate & proof: A verifiable certificate (e.g., with QR code, as with REP27) makes communication with marketplaces and authorities easier.
- Response time: How quickly is the appointment made? REP27, for example, issues within 24 hours.
- Pricing structure: Are all services included, or are there extra charges per product, inquiry, or certificate?
- Experience with your product category: Providers should be familiar with your industry, especially for high-risk categories like toys, electronics, or cosmetics.
Some providers, like Responsible Person Finder, only compare and refer, not actually appoint. Make sure the provider covers your product category and business model. For complex supply chains (e.g., white-label or import), it's vital that the provider understands the manufacturer's role and obligations.
Compare providers using the table and check if all relevant services are included. Ask specifically about extra costs, liability limitations, and cancellation terms.
What is included in the price? (Service comparison & pitfalls)
Provider services can differ significantly. Not every service covers all GPSR obligations. A detailed comparison helps avoid hidden costs and gaps:
| Provider | Included | Not included | Extra fees |
|---|---|---|---|
| REP27 | Appointment, verifiable certificate, label address, retention of technical docs, forwarding of inquiries | Legal advice, DPO service, compliance check | None (per website) |
| GPSR-Guard | Documentation, authority contact | Unknown | On request |
| GPSR Kit | Documentation, authority contact | Unknown | On request |
| Ax Holding Group | Authority contact, compliance support | Unknown | On request |
| Responsible Person Finder | Provider comparison, referral | Actual appointment | On request |
Key differences:
- REP27 covers all products and inquiries, no extra fees per SKU or inquiry (per website).
- Other providers only give prices and extras on request. Always ask about hidden costs, e.g., for additional product certificates, documentation checks, or per inquiry.
- Legal advice, compliance checks, or DPO services are not included with any provider's standard package.
Check if your provider can respond quickly in urgent cases and whether technical documentation is always accessible. Pay attention to certificate format and whether marketplaces like Amazon accept it.
Decision matrix: Who needs a Responsible Person?
Whether you need a Responsible Person under GPSR depends on your business model, location, and role in the supply chain. The following matrix helps clarify:
| If you are ... | You need ... | You don't need ... |
|---|---|---|
| Manufacturer outside the EU, selling to EU consumers (B2C, e.g., Amazon, Shopify) | Responsible Person under GPSR Art. 16 | – |
| Manufacturer outside the EU, selling only B2B (wholesale, not to end customers) | Usually yes, as GPSR covers B2B too | – |
| EU manufacturer | – | No, your own address suffices |
| Only on marketplaces (Amazon, Etsy, eBay) with EU warehouse | Yes, required by marketplace | – |
| Only digital products/SaaS | No | Yes |
| Reseller of only EU products | Usually no (manufacturer's obligation) | Yes |
Examples:
- A Chinese Amazon seller shipping own brand products to the EU must appoint a Responsible Person.
- A US company selling only software is not affected.
- A UK seller with white-label products (own brand on third-party goods) is considered a manufacturer and must appoint a Responsible Person.
If unsure, consult the provider—but note that legal advice is not included in the service.
Checklist: 6 steps to compliance
- Check your role: Are you a manufacturer, importer, or reseller? Is your name on the product or packaging?
- Select the right provider: Use the comparison table to choose a provider with EU presence and full service scope.
- Sign the contract: Provide the required company and product information. With REP27, appointment and certificate are issued within 24 hours after payment.
- Implement the details: Add the Responsible Person's name and address to the product, packaging, leaflet, and your Amazon listing. Ensure the info is available in all relevant languages.
- Prepare technical documentation: Keep the declaration of conformity, risk assessment, and technical documents ready and provide them to the Responsible Person.
- Keep everything updated: Keep information current, respond to authority requests, and update documentation when products change.
Important: When switching providers, secure the new appointment first, then update the details, and only then cancel the old contract. This avoids listing gaps.
What providers often don't tell you (exclusions, deadlines, liability)
- Extra costs: Many providers charge per product, per inquiry, or for extra certificates. REP27 covers all products and inquiries per their website; others provide prices only on request.
- Liability: Appointment as Responsible Person does not relieve you of manufacturer liability. Authorities can still contact your company directly. The Responsible Person is just a contact and document holder.
- Scope of service: Legal advice, compliance checks, and DPO services are not included in any standard package. You only get the formal appointment and forwarding of inquiries.
- Cancellation periods: When switching providers, ensure there is no gap. REP27 requires proof of previous appointment and takes over documentation seamlessly.
- Documentation duty: Complete technical documentation must be provided by the manufacturer. The Responsible Person only stores and forwards it.
Ask specifically about these points before choosing a provider. Also check how communication works in urgent cases (e.g., product recalls) and whether the provider has experience with your product category.
Risks & fines for non-compliance
The consequences of missing or incorrect appointment are significant:
- Listing deactivation: Amazon and other marketplaces are required to deactivate listings without proper Responsible Person details (Source).
- Authority action: Market surveillance authorities can remove products from the market, order recalls, or impose fines.
- Fines: GPSR provides for substantial penalties in case of violations. The Responsible Person must cooperate with authorities and provide technical documentation in case of safety issues (Source).
- Reputation risk: Lack of compliance can lead to negative reviews, reputational damage, and loss of customer trust.
Appointing a Responsible Person is not just a legal obligation but also protects your business from costly interruptions and sanctions. For Amazon sellers from non-EU countries, compliance is mandatory, as marketplaces enforce these rules automatically and strictly.
Three real-world scenarios (concrete examples)
- US SaaS provider: Sells only digital products (e.g., software, cloud services) to EU customers. No obligation to appoint a Responsible Person under GPSR, as no physical products are sold.
- Chinese Amazon seller: Lists own brand products on Amazon.de and stores them in an EU fulfillment center. Must appoint a Responsible Person based in the EU; name and address must appear on the product, packaging, and Amazon listing. Technical documentation is provided to the Responsible Person. REP27 issues the appointment within 24 hours.
- UK online shop with private label: Post-Brexit, the company is a third country. Sells white-label products (own brand on purchased goods) via Amazon and its own shop to EU customers. Also needs a Responsible Person in the EU. Providers like REP27 or GPSR-Guard offer this service; complete technical documentation must be provided.
These examples show: The obligation depends not on the sales channel but on your role as manufacturer/importer and your location outside the EU. Check your supply chain and product labeling carefully.
When you do not need this
- Manufacturers based in the EU (own address is sufficient)
- Resellers only selling EU products and not acting as manufacturer
- Sale of digital products only (e.g., SaaS, software downloads)
Frequently asked questions
Who must appoint a Responsible Person under GPSR?
All manufacturers from non-EU countries selling physical products to consumers or distributors in the EU must appoint a Responsible Person based in the EU. This applies regardless of whether sales are via Amazon, own shops, or other marketplaces.
What happens if I don't provide a Responsible Person?
Amazon may deactivate your listings. Authorities can remove products from the market or impose fines. The Responsible Person is mandatory under GPSR Art. 16 and Art. 19.
How fast is the appointment with REP27?
According to REP27, the appointment and certificate are issued within 24 hours after contract and payment. You can then update your listings and product details promptly.
Does the Responsible Person's address have to be on the product?
Yes. Article 19 GPSR requires the name and address of the Responsible Person to be on the product, packaging, and listings. The information must be permanent and easily readable.
What does the service cost?
Prices range depending on provider and scope from €150 to €890 per year (as of October 2026). Some providers only give prices on request. With REP27, all products and inquiries are included in the price.
Who is liable in case of problems?
The Responsible Person is a contact for authorities, but product safety liability remains with the manufacturer. Appointment does not replace compliance checks or relieve you of responsibility for product safety.
Can I change the Responsible Person?
Yes. Changing is possible but should be seamless. REP27 requires proof of previous appointment and takes over documentation smoothly. Only cancel the old contract after the switch is complete.
Do I need the service for B2B sales?
Usually yes, as GPSR also applies to wholesale if you act as manufacturer and place products on the EU market for the first time. The obligation exists regardless of sales channel.
What about white-label products?
As soon as your name or brand appears on the product, you are considered the manufacturer and need a Responsible Person in the EU. This also applies if you sell third-party products under your own name.
Are there differences between marketplace and own shop sales?
No, the obligation applies regardless of sales channel. However, marketplaces like Amazon enforce compliance more strictly and deactivate listings for violations. The information is also required in your own shop.
Which documents must I provide?
You must have complete technical documentation and a declaration of conformity for each product and provide them to the Responsible Person. They must retain the documents for 10 years.
What if I only sell digital products?
For purely digital products (e.g., software, SaaS), there is no obligation to appoint a Responsible Person under GPSR, as the regulation only applies to physical products.
Sources
- REP27 — Europe Services, SE: GPSR Responsible Person — gdprrepresentative.com
- GPSR-Guard: Responsible Person Art. 16 — gpsr-software.de
- GPSR Kit: EU Responsible Person Cost — gpsr-kit.com
- Ax Holding Group: GPSR Responsible Person for Amazon — axholdinggroup.com
- Responsible Person Finder — responsiblepersonfinder.com