RP16

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Regulation (EU) 2023/988 · Article 16

If your company is not established in the Union, the rule is written for you.

The requirement exists precisely because the seller is elsewhere. Whether you ship from Shenzhen, Ohio or Manchester, the Union expects a name inside its borders that answers for the product.

Enforcement file leading to a product recall — GPSR non-EU sellers China US UK
Enforcement file leading to a product recall.

Sellers in China and the rest of Asia

Volume manufacturing into EU marketplaces is the most heavily checked flow, and the compliance field is enforced at listing level rather than at the border alone.

Suppliers frequently offer a certificate that names a different model or a lapsed standard, so the certificate is worth reading rather than filing.

Sellers in the United States

American sellers are often caught by the assumption that a domestic safety approval carries weight in the Union. It does not: the standards differ and so does the paperwork.

The practical route is a European file built for European rules, not a translation of the American one.

Signing the written mandate for a responsible person — GPSR non-EU sellers China US UK
Signing the written mandate for a responsible person.

Sellers in the United Kingdom

Since leaving the Union, a British company is a non-EU seller for these purposes and needs an operator established in a member state, whatever its history of trading into Europe.

Northern Ireland follows the Union rules under separate arrangements, which is a distinction worth checking rather than assuming.

What you can show an inspector

A mandate with a date and a signature, an address that answers, and a code that an inspector can resolve on the spot from a phone.

That is the whole point of the service: it survives contact with someone checking.

What separates this from the cheap offers

The cheapest providers sell you an address and a PDF. Neither survives a check, because neither can be confirmed from outside.

We publish a status that we cannot quietly edit after the fact, and that is the part competitors do not offer.

Questions we are asked

I am in the UK and have sold into Europe for years. Has anything changed?

Yes. A UK company is now established outside the Union, so the requirement to name an operator inside a member state applies to your products.

Does a US safety approval help me in Europe?

Not directly. The standards and the documentation differ, and a European file has to stand on European evidence.

My Chinese supplier says the product is CE certified. Is it?

Sometimes, and sometimes the certificate names another model or an outdated standard. Read it against the exact product you are shipping before relying on it.

Being outside the Union is not the problem the rule is trying to solve. Being unreachable is.

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