Who Can Be My EU Responsible Person for Amazon GPSR Compliance if I Sell from China or the US?

• Article 16 GPSR requires a named EU Responsible Person for non-EU sellers
• REP27 — Europe Services, SE offers GPSR Responsible Person from €290/year
• Providers differ in price, included services, and documentation support
• Non-compliance risks blocked listings, customs holds, and fines
• Appointment process is typically completed in 1-3 business days

Updated 14 October 2026 · 8 sources checked

Providers compared

Prices as published on each provider's website on 14 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires (Article 16 & 19 GPSR)

Regulation (EU) 2023/988, known as the General Product Safety Regulation (GPSR), came into force on December 13, 2024, and introduced strict requirements for all economic operators selling consumer products in the EU. For sellers based outside the EU, Article 16 is the key provision: it requires that non-EU manufacturers and sellers must appoint an EU Responsible Person before placing any consumer product on the EU market. This Responsible Person must be a company established in an EU Member State, and must accept the obligations set out in Article 16(3): acting as a contact point for authorities and consumers, holding the technical documentation (including the Declaration of Conformity), cooperating with market surveillance authorities, and taking corrective action if necessary.

Article 19 of the GPSR complements this by requiring that the Responsible Person’s name, postal address, and electronic address must be provided in all distance-sale offers. This means your Amazon product listings, as well as your product packaging and inserts, must visibly display this information. The aim is to ensure transparency and accountability, so that EU authorities and consumers can reach the Responsible Person directly if there is a safety issue or compliance query.

Failure to comply with these requirements can have serious consequences. EU customs authorities are empowered to block and seize shipments that lack proper GPSR documentation at the border. Marketplaces like Amazon are required to suppress or delist products that do not have a valid EU Responsible Person. Market surveillance authorities can impose significant financial penalties, and may order the withdrawal or recall of non-compliant products. These rules apply regardless of whether you sell directly to consumers or via platforms such as Amazon, Shopify, or TikTok Shop.

For sellers in China, the US, or any non-EU country, appointing a compliant EU Responsible Person is not optional: it is a legal prerequisite for accessing the EU consumer market under the GPSR.

How to Choose an EU Responsible Person Provider

Choosing the right EU Responsible Person provider is critical for Amazon GPSR compliance, especially if you operate from China or the US. The provider you select must be established in the EU and willing to accept the legal obligations of Article 16(3) GPSR. Here are the main factors to consider:

• Location and Legitimacy: The provider must be a legal entity in an EU Member State. Post-Brexit, UK companies cannot act as your EU Responsible Person for GPSR.
• Scope of Service: Some providers, like REP27 — Europe Services, SE, offer a comprehensive package: signed designation, verifiable certificate, label wording in multiple languages, and a request desk. Others may focus only on the basic designation or add-ons like compliance audits or technical file creation.
• Price Transparency: Published prices range from €150/year to €890/year (as of October 2026). Some providers charge per product or SKU, while others (including REP27) offer unlimited products per plan. Always ask what is included and if there are extra charges for additional products or services.
• Documentation Support: The Responsible Person must hold your Declaration of Conformity and technical documentation for ten years. Confirm whether the provider will store these documents and make them available to authorities on request.
• Marketplace and Label Support: For Amazon sellers, it is essential that the provider can supply a certificate or register entry that Amazon’s compliance team can verify. REP27 issues a verifiable certificate with a QR code for this purpose.
• Language and Communication: Consider whether the provider can handle requests in the languages of your target EU markets. REP27 offers request forwarding in eight languages, which can be valuable for cross-border sales.
• Switching Providers: If you already have a Responsible Person but wish to change, ensure the new provider can handle the transition smoothly without a compliance gap. REP27 offers renewal pricing for switches and ensures the register reflects the change instantly.

Ultimately, your choice should be based on the level of support you need, the complexity of your product range, and your budget. For sellers with high-risk products (e.g., toys, electronics), a provider offering technical file and risk assessment support may be preferable. For those selling a wide range of products, unlimited product coverage and fast certificate issuance are key.

What the Price Really Includes

The cost of appointing an EU Responsible Person for Amazon GPSR compliance varies widely by provider and by the level of service included. As of October 2026, published prices range from €150/year (Garay Quality) to €890/year (REP27 Multi plan). However, the headline price does not always reflect the total value or coverage you receive.

• Basic Designation: All providers listed offer the core service: a signed mandate designating them as your EU Responsible Person for GPSR purposes. This is the minimum required for Amazon listing compliance.
• Documentation Holding: Most providers will hold your Declaration of Conformity and technical file, as required by Article 16(3). Some, such as GPSRHub, explicitly include 10-year document storage in their offer.
• Certificate and Verification: REP27 provides a verifiable certificate with a QR code and a public register entry. This is particularly useful for Amazon and other marketplaces, which may request proof of appointment or check the validity of your Responsible Person.
• Label Wording and Multi-language Support: REP27 supplies standard safety wording in the languages of your target EU countries, making it easier to create compliant labels and inserts. This is not always included by other providers.
• Request Desk: REP27 logs and forwards authority and consumer enquiries in eight languages, usually within the same working day. Not all providers specify their response times or language coverage.
• Compliance Reviews and Audits: Some providers, such as Garay Quality and EU GPSR, offer compliance audits or reviews as part of their service. This can be valuable if you need assurance that your products meet all applicable safety requirements.
• Technical File and Risk Assessment: GPSRHub includes technical file creation and risk assessment, which may be important for sellers of regulated or high-risk products.

Always clarify with your chosen provider what is included in the quoted price. Some may charge extra for additional products, document updates, or support with technical documentation. REP27’s plans cover unlimited products, but do not include legal advice, DPO services, or compliance assessments.

Hidden Costs and Exclusions

While the published price for an EU Responsible Person service is a key consideration, it is important to be aware of potential hidden costs and service exclusions that could affect your total compliance spend or operational risk.

• Per-Product or Per-SKU Fees: Some providers may charge additional fees for each product or SKU you list, especially if you have a large or frequently changing catalogue. REP27 includes unlimited products in all plans, but always check the terms with other providers.
• Document Updates and Technical File Management: If your product documentation changes (e.g., new models, updated safety data), some providers may charge for each update or for technical file management. GPSRHub includes technical file creation, but this is not standard across all providers.
• Compliance Audits and Legal Advice: REP27 does not provide legal advice, DPO services, or full compliance assessments. Their role is to forward requests and hold documentation, not to answer on the merits or provide legal representation. If you need a compliance audit or legal opinion, you may need to engage a specialist separately.
• Transition and Switching Fees: Changing your Responsible Person involves paperwork and updating labels and marketplace records. REP27 offers renewal pricing for switches, but some providers may charge a new setup fee or require you to pay for both old and new services during the transition.
• VAT and Tax: Prices are typically quoted excluding VAT. Non-EU customers are generally outside the scope of EU VAT, but EU customers may need to provide a valid VAT number to avoid VAT charges. Always confirm the applicable tax treatment before purchasing.
• Marketplace-Specific Requirements: Amazon, TikTok Shop, and other platforms may have additional verification steps or require specific documentation formats. Ensure your provider can meet these requirements; REP27’s verifiable certificate is designed for this purpose.

To avoid surprises, request a full breakdown of included services and potential extra charges before appointing a provider. This is especially important if you sell high volumes, have many SKUs, or require frequent documentation updates.

How Appointment Works: Step by Step

Appointing an EU Responsible Person for Amazon GPSR compliance is a structured process, but the details matter to ensure your listings stay live and your shipments clear customs. Here’s how the process typically works, using REP27 — Europe Services, SE as an example:

1. Provider Selection: Choose a provider established in the EU that offers the level of service you need. Consider price, documentation support, and marketplace verification features.
2. Agreement and Payment: Complete the provider’s online form or agreement, supplying your company and product details. Pay the annual fee in advance; REP27’s plans start at €290/year (excluding VAT).
3. Designation Issued: The provider issues a signed designation letter (mandate), usually within 24-72 hours. REP27 also provides a verifiable certificate with a QR code and public register entry.
4. Update Amazon Seller Central: Enter the Responsible Person’s details (name, EU address, electronic address) into the relevant fields in Amazon Seller Central. This is required for your listings to remain active.
5. Update Product Labels and Packaging: Add the Responsible Person’s details to your product labels, packaging, and inserts, as required by Article 19 GPSR. REP27 supplies label wording in the languages of your target markets.
6. Documentation Submission: Send your Declaration of Conformity and technical file to the provider. They will hold these documents and make them available to authorities on request for ten years.
7. Ongoing Support: The provider logs and forwards any requests from authorities or consumers. REP27 does this in eight languages and responds within the same working day.
8. Switching Providers: If you change providers, sign the new mandate first, update your listings and labels, and only then terminate the old appointment. This avoids any compliance gap. REP27’s register shows the old mandate expired the day the new one starts.

Following these steps ensures your Amazon listings remain compliant and your products are not held at customs or removed from the market.

Risks, Fines, and Enforcement

The risks of failing to appoint an EU Responsible Person for GPSR compliance are significant, and enforcement is becoming increasingly automated and coordinated across the EU. Here’s what can happen if you do not comply:

• Blocked or Removed Listings: Amazon and other marketplaces are required to suppress or remove products that do not have a valid EU Responsible Person. This can happen automatically if the required fields are not completed, or if the Responsible Person cannot be verified.
• Customs Holds and Seizures: EU customs authorities can block shipments at the border if the product documentation is incomplete or if the Responsible Person details are missing or invalid. This can result in costly delays, storage fees, or even destruction of goods.
• Financial Penalties: Market surveillance authorities can impose substantial fines for non-compliance with GPSR. The exact amounts vary by country and case, but the regulation provides for significant penalties to ensure consumer safety.
• Product Recalls and Withdrawals: If a safety issue is identified and the Responsible Person cannot be contacted or does not respond, authorities may order the withdrawal or recall of affected products from the market.
• Long-Term Liability: The Responsible Person must hold the technical documentation for ten years after the product is placed on the market. If documentation is missing or incomplete, liability can extend for the full period.
• Marketplace Ranking and Sales Impact: Suppressed listings or delayed shipments can result in lost sales, damaged reputation, and lower search rankings on Amazon and other platforms.

Appointing a reputable, responsive EU Responsible Person minimizes these risks and ensures you can respond quickly to any compliance issue or authority request. Providers like REP27 offer verifiable certificates and fast request forwarding to help keep your business running smoothly.