How to Appoint a Responsible Person Under GPSR

You already know that your products from China need a Responsible Person (RP) established in the EU. But what does "appointing an RP" actually mean in practice? Do you need to sign some kind of agreement? Is it enough that you're a Polish trader? Or do you need to buy in an external company's service? Allegro sellers often get stuck in uncertainty here, because the GPSR regulation (EU) 2023/988 says "a Responsible Person must exist" but doesn't give step-by-step instructions. This article explains how to appoint an RP in practice in the typical importer scenarios.

First, work out where you sit in the chain

Before you "appoint" an RP, check whether you might already be one yourself. That's the most common scenario. GPSR sets out an order of entities that can be the Responsible Person — more in our article on the Responsible Person — when it's required. The key question: who actually places the product on the EU market?

• You import from China and sell as a Polish company → you're the importer, i.e. the Responsible Person.
• A manufacturer from outside the EU wants to be responsible for the product itself → it appoints an authorised representative in the EU.
• You buy from an EU distributor who is already the importer → the RP is already established earlier in the chain.

Scenario 1: you're the importer — you're the RP

If you're the one importing goods from outside the EU and placing them on the market, the Responsible Person role falls to you automatically — you don't need to sign an agreement with yourself. "Appointment" here means fulfilling the RP's obligations and providing your details. Practical steps:

1. Confirm your importer status — you're the one clearing the goods and placing them on the market.
2. Gather and verify documentation — technical documentation, risk assessment, standards.
3. Put your details on the product and in the listing — name, address, contact.
4. Ensure documentation is available — on request from the surveillance authority.

Scenario 2: a manufacturer outside the EU appoints a representative

When the manufacturer wants to be responsible for the product, it establishes an authorised representative in the EU on the basis of a written mandate. In this case, the appointment is formal — an agreement/power of attorney setting out the scope of duties is needed. This variant more often applies to larger manufacturers than to a seller importing small goods from China.

Scenario 3: you buy an external RP service

Companies offering an "RP as a service" for manufacturers from outside the EU have appeared on the market. This is an option when a manufacturer wants to keep the status of the party placing the product on the market but doesn't want to set up an entity in the EU. For a typical Polish importer, this usually isn't needed — because the importer is already the Responsible Person anyway. Comparison of the routes:

Route	Who it's for	Formalities
Importer = RP	Seller importing goods from China	No agreement with yourself; fulfilling RP obligations
Authorised representative	Manufacturer from outside the EU	Written power of attorney, agreement
External RP service	Manufacturer from outside the EU with no EU entity	Agreement with the service provider, a fee

What you need to have to hold the RP role

Regardless of the route, the Responsible Person must genuinely fulfil the obligations. The minimum is:

• access to complete technical documentation for the product,
• the ability to make it available to the surveillance authority on request,
• readiness to act in the event of a hazard (repair, notification, withdrawal),
• contact details provided on the product and in the listing.

A necessary condition is traceability — without batch numbers, you can't respond effectively. More on that in our article on product traceability.

Common mistakes when appointing an RP

Sellers most often trip up on:

• believing the supplier from China will "sort out the RP" — it can't, the RP must be in the EU,
• failing to put their own details on the product and in the listing despite being the importer,
• treating the RP as a "paper" formality with no real access to the documentation,
• buying an external RP service where they're already the importer themselves — an unnecessary cost.

Frequently asked questions

Do I need to sign an agreement to be the Responsible Person?

If you're the importer placing the product on the market, the RP role falls to you automatically — with no agreement with yourself. An agreement (power of attorney) is needed when a manufacturer from outside the EU appoints an authorised representative.

Is an external RP company mandatory?

No. This solution is mainly for manufacturers from outside the EU with no entity in the Union. A Polish importer usually holds the Responsible Person role themselves and doesn't need an external service.

Can one company be the RP for multiple products?

Yes. The same entity can be the Responsible Person for a whole product range, as long as it has access to the documentation and fulfils the RP obligations for each product.

What if I also sell in other EU countries?

A Responsible Person established in one EU member state acts for the entire EU market. However, you still need to take care of language requirements for instructions and warnings in each country where you sell.