RP for a Non-EU Seller: Responsibilities

Picture a seller from Ukraine, or a company based in the UK, that has been selling small electronics and household accessories on Allegro for years. Sales are going great, until the platform sends a message: "Your listings will be hidden unless you provide a responsible entity in the EU." This isn't a system error. It's a direct consequence of the GPSR (EU) 2023/988 regulation, in force since 13 December 2024, which requires every consumer product sold in the Union to have a so-called Responsible Person (RP) established within the EU.

Who counts as a non-EU seller under GPSR

A non-EU seller is any entity established outside the borders of the European Union that offers products to consumers in member states. This applies both to Chinese manufacturers shipping goods directly (dropshipping and fulfilment models) and to companies from the UK, Ukraine, the US or Switzerland selling through a marketplace or their own shop.

The core GPSR principle is simple: a consumer product cannot be placed on the EU market unless there is an entity established in the EU that takes responsibility for its safety. Without such an entity, the product is formally illegal, and the platform is obliged to remove the listing.

What is a Responsible Person (RP)

A Responsible Person is an economic operator established within the Union that acts as a contact point for market surveillance authorities. The RP doesn't have to be a natural person — in practice it's most often a company. The following can act as RP:

• The manufacturer, if established in the EU,
• The importer, i.e. the EU entity that first places a product from outside the Union on the market,
• An authorised representative designated in writing by a manufacturer from outside the EU,
• A fulfilment service provider, if none of the above entities exist.

For a non-EU seller, the most common solution is to appoint an authorised representative or to work with an importer who takes on the RP function.

Responsibilities of the Responsible Person

The RP is not merely a correspondence address. Regulation 2023/988 imposes concrete duties on this entity:

• verifying that the manufacturer has drawn up technical documentation and carried out a risk assessment,
• storing the technical documentation for 10 years from the product being placed on the market,
• providing market surveillance authorities with safety evidence on request,
• cooperating with authorities on corrective actions (withdrawal, recall of the product),
• informing the authorities if the RP considers that a product poses a risk.

What must appear on the product and in the listing

GPSR requires that the RP's details be visible to the consumer before the purchase is made. In practice, this means the following information must appear in the listing and on the product or its packaging:

Information	Where it must appear
Name and address of the EU RP	On the product/packaging and in the online listing
Email address or other contact for the RP	In the online listing and documentation
Name and address of the manufacturer	On the product or packaging
Batch number, model or product identifier	On the product/packaging
Warnings and safety instructions	In the language of the country of sale (for Poland: in Polish)

RP versus importer, manufacturer and seller — how it fits together

In practice, sellers often confuse the roles of entities in the supply chain, but GPSR clearly separates them. The manufacturer designs and produces the product and draws up the technical documentation. The importer is the EU entity that first places a product from outside the Union on the EU market, and it is this entity that most often becomes the RP by default. The distributor makes the product available further down the chain and verifies that it carries the required markings and RP details. The retailer, offering the product to the consumer, is responsible for making sure the RP information and warnings are visible in the listing. A single entity can combine several roles at once — for example, an importer is often simultaneously a seller and the RP. What matters is that somewhere in this chain there must be an entity established in the EU that takes responsibility for the product's safety.

For a company from China, the UK or the US selling directly to consumers in the EU (for example, shipping from a warehouse outside the Union), the natural solution is to appoint an authorised representative in writing. An alternative is to work with an importer who buys the goods wholesale, places them on the EU market, and takes on the RP function. The choice of model depends on the scale and structure of sales, but in every variant a real entity in the EU is needed — not just a virtual address.

Consequences of not having an RP

A non-EU seller who fails to designate a Responsible Person exposes themselves to several levels of risk. First, platforms such as Allegro, Amazon or Kaufland block or hide listings lacking RP details, which means an immediate drop in sales. Second, market surveillance authorities (in Poland, among others UOKiK and the Trade Inspection) can order the withdrawal of the product and impose administrative penalties. Third, in the event of an accident involving the product, the lack of an RP further worsens the seller's legal position, because there is no entity in the EU to take on responsibility and cooperate with the authorities. It's worth remembering that this responsibility doesn't disappear once sales end — the documentation must remain available for 10 years.

We cover the costs of this solution in more detail in the article How much does a Responsible Person (RP) cost, and the obligations on a specific platform in GPSR on Amazon — requirements and how to meet them.

How to prepare step by step

The recommended sequence of actions for a non-EU seller is as follows:

• establish who in your chain can act as RP (importer, representative, fulfilment provider),
• conclude a written authorisation with the RP and obtain their details for publication,
• collect the technical documentation and risk assessment from the manufacturer,
• update labels and listings with RP details and warnings in Polish,
• complete the RP details in the platforms' seller panels.

Frequently asked questions

Is a seller from the UK treated as a non-EU entity?

Yes. Following Brexit, the UK is a third country, so a UK seller must designate an RP established in the Union, exactly the same as a seller from China or the US.

Can I be my own Responsible Person if my company is based outside the EU?

No. By definition, the RP must be established within the European Union. A company from outside the EU must designate a separate entity in the EU (an importer or an authorised representative).

Can one RP handle multiple products?

Yes. The same authorised representative or importer can act as RP for an entire product range, as long as they hold the technical documentation for each product.

What are the consequences of selling without designating an RP?

Listings get blocked on platforms, market surveillance authorities can order the product's withdrawal, and administrative penalties can be imposed. In the event of harm caused by the product, the lack of an RP increases the seller's liability.