What Is a Responsible Person?
A Responsible Person is a legal entity or qualified individual based in the EU or UK, officially designated to ensure your products comply with all relevant safety regulations. This role is pivotal under the EU’s General Product Safety Regulation (GPSR), which came into force on December 13, 2024, and under UK law for certain regulated products
Key Functions of the Responsible Person:
- Primary contact for authorities: Handles all communications with EU/UK regulators and market surveillance authorities
- Documentation management: Maintains technical files and compliance documents, ready for inspection at any time
- Post-market surveillance: Monitors products after launch, manages incident reporting, and coordinates recalls or corrective actions if necessary
- Labeling and information: Ensures your products are properly labeled with the RP’s details and all required safety information
- Cooperation with authorities: Provides requested documentation and supports investigations or corrective actions
Who Needs to Appoint a Responsible Person?
- Non-EU sellers must appoint an EU Responsible Person to sell any non-food goods in the EU
- Non-UK manufacturers must appoint a UK Responsible Person (UKRP) to place regulated products (e.g., medical devices) on the market in Great Britain
- Cosmetics, medical devices, and other regulated categories have their own RP requirements under sector-specific regulations
How to Appoint a Responsible Person: Step-by-Step
1. Choose a Qualified Entity
- The RP can be an authorized representative, importer, manufacturer (if EU/UK-based), or a fulfillment service provider
- The RP must be established and operational in the EU or UK, not just a mailbox or unqualified individual
2. Negotiate and Formalize the Relationship
- Sign a formal agreement outlining roles, responsibilities, and fees.
- Ensure the RP understands your products and compliance obligations.
3. Provide All Required Documentation
- Share technical files, declarations of conformity, safety data, and labeling templates.
- The RP must have access to up-to-date documentation at all times
4. Update Product Labels and Listings
- Clearly display the RP’s name and contact details on product packaging, instructions, and digital listings
- This information should be visible to buyers before purchase and available for customs or market surveillance checks
5. Ongoing Collaboration
- Respond promptly to RP requests for information or corrective action.
- Review the RP’s performance regularly to ensure continued compliance
Why Is the Responsible Person So Important?
- Legal market access: Without an appointed RP, non-EU/UK sellers cannot legally sell in these markets. Marketplaces like Amazon now require proof of an RP before listing products
- Regulatory protection: The RP shields your business from direct regulatory action, acting as your local representative in case of inspections, recalls, or incidents
- Consumer trust: Transparent labeling and a local contact point reassure buyers and authorities of your commitment to safety and compliance
What Happens If You Don’t Appoint an RP?
- Product removals: Customs or market surveillance authorities can block or remove your products from the market
- Marketplace suspensions: Amazon and other platforms may deactivate your listings
- Fines and legal action: Non-compliance can lead to significant penalties and reputational damage
Final Tips for Sellers
- Don’t cut corners: Only appoint reputable, experienced RPs—avoid using friends, mailbox services, or unqualified contacts
- Budget for compliance: RP services typically start at around $500/year, but costs can vary based on product type and service level
- Stay proactive: Regularly review your RP relationship and compliance status, especially as regulations evolve.
Appointing and working with a Responsible Person is not just a legal requirement—it’s a strategic move to safeguard your business, build trust, and ensure seamless access to the lucrative EU and UK markets.
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Sources: EU Compliance Partner, Med-Di-Dia, UKARA, TBA Global, PRODlaw.eu, EcoMundo, UKRP Services