GPSR and the EU Responsible Person: a practical guide

The General Product Safety Regulation (Regulation (EU) 2023/988), which applies from December 2024, reshaped a rule that many non-EU sellers had treated as optional: for a broad range of consumer products, there must be a designated economic operator established in the Union who is responsible for defined safety-related tasks. This is the EU Responsible Person, and for many agencies it has become a fast-growing line of business alongside EPR.

This guide sets out what the role requires, where the practical difficulty lies, and how to run it as a repeatable service rather than a series of one-off arrangements. It is general information, not legal advice — but it should help you frame the obligations correctly.

Which products need a Responsible Person

The GPSR applies to consumer products that are not already governed by sector-specific safety legislation, and it operates as a safety net beneath that sector legislation. In practice, a great many general consumer goods — from homewares to textiles to non-regulated electronics accessories — fall within its scope. The trigger for needing a Responsible Person is placing such products on the EU market when there is no manufacturer, importer or authorised representative already established in the Union to carry the duties.

For online sellers in particular, this catches a large population of non-EU businesses that ship directly to EU consumers. Marketplaces increasingly require a valid Responsible Person before a listing can go live, which is why demand has moved quickly from a legal nicety to a commercial gate.

The core duties

The Responsible Person's obligations cluster around evidence and contactability. The essential tasks are:

• Verifying that the required technical documentation exists and that a declaration or safety information has been drawn up, and keeping that documentation available to authorities for the required period.
• Ensuring the product carries the necessary identification and the Responsible Person's contact details, so that a consumer or authority can reach a real point of contact in the Union.
• Cooperating with market surveillance authorities on any action to eliminate or mitigate risks presented by the product.
• Informing authorities and, where appropriate, the public if the Responsible Person has reason to believe a product presents a risk.

None of these is intellectually hard. The difficulty is operational: each duty generates documents that must be held, kept current, and produced on demand — potentially years after a product was first placed on the market, and across a portfolio of many clients and thousands of SKUs.

The ten-year documentation reality

The obligation that most often catches agencies out is retention. Technical documentation associated with GPSR obligations can need to be retained for up to ten years after a product is placed on the market. That is a long time to keep a specific version of a specific file retrievable, intact and associated with the right product and client.

This is precisely where a versioned document vault earns its keep. Files stored as immutable versions with integrity checksums — so a document cannot be silently altered — and with retention policies that prevent premature deletion, turn a ten-year obligation from an anxiety into a background guarantee. The alternative, a shared drive full of folders named by hand, is the kind of arrangement that fails an audit at the worst moment.

Running it as a service, not a scramble

The agencies that make the Responsible Person role profitable treat it as a standardised workflow. A new client's onboarding produces a checklist of the documentation to collect; the missing items become requests sent through a branded client portal; uploaded files land in the vault with their retention clock set; and the contactability obligation is satisfied by a monitored channel rather than a personal inbox.

Because GPSR obligations sit alongside EPR obligations for the same clients — the online seller who needs a Responsible Person very often also has packaging and WEEE duties — there is real efficiency in managing both in one system. A single client record that carries the GPSR documentation and the EPR calendar means one onboarding, one portal, one place to look.

A common mistake is to treat the Responsible Person's contact details as a set-and-forget field. If market surveillance contacts that channel and receives no timely response, the value of the entire arrangement collapses. Route it somewhere monitored, and log the correspondence against the client so there is evidence of cooperation.

Bringing it together

The Responsible Person role is, at heart, a promise to hold evidence and be reachable. Software cannot make that promise for you, but it can make it dependable: a document vault that guarantees retention, a portal that collects what you need, and an audit trail that proves you did what you said. Complywerk handles GPSR documentation and EPR obligations in the same client record, so a growing Responsible Person practice does not become a growing filing problem.

To see how the document vault and portal work in practice, start with the product overview.