Responsible Person Under GPSR: When Is It Required?

You run a shop on Allegro and import small electronics from China. Your supplier sits in Shenzhen, and you list products under your own brand. The marketplace sends a message: "For products covered by GPSR, a Responsible Person based in the EU is required. Provide their details, or the listing will be blocked." Your first thought: "but I'm in Poland, surely that's enough?". This is where the confusion starts. The Responsible Person (RP) is a specific institution set out in the GPSR regulation (EU) 2023/988 — Article 16. This article explains when it's required and who can act as one.

What the Responsible Person (RP) is

The Responsible Person is an entity established in the European Union that handles specific obligations related to product safety. GPSR states in Article 16 that a product from outside the EU can only be placed on the market if there is a trader in the EU responsible for that product. The point is that for every product there is a "point of contact" within the Union — someone the market surveillance authority and the consumer can turn to.

This isn't a natural person in the sense of an "employee" — it's a legal role that a company can hold. The key thing is one thing only: being established in the EU.

When an RP is required

The requirement arises when a product covered by GPSR is placed on the EU market and the manufacturer is established outside the Union. Typical situations:

• Importing from China and selling in the EU — the most common case for Allegro sellers.
• Dropshipping from countries outside the EU — the product reaches a consumer in the EU.
• Selling under your own brand (private label) goods manufactured outside the Union.

In these scenarios, there must be an entity in the EU responsible for the product. Without this, the product formally cannot be placed on the market — and marketplaces like Allegro enforce this by blocking listings that lack RP details.

Who can act as the Responsible Person

The regulation names several entities that can be the Responsible Person. The order matters in practice:

Entity	When it holds the RP role
Manufacturer established in the EU	When it manufactures in the EU itself
Importer established in the EU	When it places a product from outside the EU on the market — a common case
Authorised representative in the EU	When a manufacturer from outside the EU appoints one in writing
Fulfilment service provider in the EU	When none of the other entities are present in the EU

If you import goods from China and place them on the market yourself as a Polish company, in most cases you — as the importer — are the Responsible Person. We describe how to confirm this in our article on appointing a Responsible Person.

What the RP is responsible for

The Responsible Person doesn't just "appear on paper" — they have real obligations. The most important include:

1. Verifying documentation — checking that technical documentation and declarations exist for the product.
2. Making documentation available to the market surveillance authority on request.
3. Cooperating in the event of a hazard — corrective action, notification, withdrawal.
4. Acting as a point of contact — RP details available to the authority and the consumer.

So they're responsible for ensuring that complete technical documentation exists and can be presented.

RP details must be visible

GPSR requires the Responsible Person's details (name, address, contact) to be given on the product or its packaging and — in marketplace practice — in the listing. Buyers and the authority must know who to contact. Details on where and how to provide this information are in our article on RP details on the product and in the listing.

What if there's no RP in the EU

If the manufacturer is outside the EU and no one in the Union holds the Responsible Person role, the product formally cannot be placed on the market. For the seller, this means the risk of listings being blocked, the product being challenged by the surveillance authority, and even liability for placing a product on the market without the required backing. That's why establishing an RP is one of the first steps before selling imported products.

Frequently asked questions

Am I the Responsible Person as a Polish importer?

In most cases, yes. If you import a product from outside the EU and place it on the market as a Polish company, you're acting as the importer, and therefore as the Responsible Person under GPSR. You then need to meet the obligations that come with it.

Can a supplier from China be the Responsible Person?

No — the Responsible Person must be established in the EU. However, a manufacturer from outside the Union can appoint an authorised representative in the EU to take on this role.

Is a separate RP needed for each product?

The RP is a role held by an entity, not by a single product — the same entity can be the Responsible Person for many products. What matters is that a Responsible Person established in the EU is assigned for each product.

Does the marketplace check RP details?

Yes. Platforms like Allegro require Responsible Person details to be provided for products covered by GPSR and can block listings that lack this information. That's a practical reason to sort out the RP question before listing products.