A brand in the UK finds a good factory in China, orders 5,000 units and ships them to a warehouse in Germany. The boxes carry the factory’s name and a Shenzhen address, and nothing else. When the listing goes live, the marketplace asks for the details of the EU responsible person, and there is none.
The fix costs far less before printing than after. This guide explains who the responsible person is, what has to appear on the product and in the listing, and what to agree with the factory before production starts.
What is the GPSR?
The General Product Safety Regulation, Regulation (EU) 2023/988, has applied since 13 December 2024. It replaced the earlier General Product Safety Directive. It covers consumer products sold in the EU, including goods sold online and shipped from outside the EU.
It works as a safety net. Some products fall under specific EU rules, such as those for toys, electrical equipment or cosmetics. For those, the specific rules apply first, and the GPSR covers the aspects and risks they leave out. The Commission decides case by case where a product sits, so check its guidelines for businesses for your product type.
Who is the EU responsible person?
Every product needs one economic operator established in the EU who answers for it. Under the Commission’s FAQ you look for that operator in this order:
| Who | When they count |
|---|---|
| The manufacturer | If the manufacturer is established in the EU |
| The importer | If the manufacturer is not in the EU, and the importer is |
| An authorised representative | If the manufacturer gives them a written mandate to act |
| A fulfilment service provider | Only if none of the above is established in the EU |
A factory in China cannot be the responsible person. If you sell to EU customers from outside the EU and you have no EU company, you have two practical choices: ask an EU importer to take the role, or appoint an authorised representative. The Commission treats an authorised representative and a responsible person as separate ideas, so the written mandate matters.
What does the responsible person do?
The responsible person checks that the technical documentation and the labelling meet the rules. Where the manufacturer is outside the EU, they also make sure any accident involving the product is notified to the authorities under Article 20 of the regulation. They are named on the product, so they carry real responsibility. Choose someone who will read the documents rather than sign them.
What must appear on the product and its packaging?
| What | Where | Notes |
|---|---|---|
| Product identifier | On the product | A type, batch or serial number, or another way to identify it |
| Manufacturer’s name and contact details | On the product or packaging | Name, postal address and an electronic address |
| EU responsible person’s name, postal and electronic address | On the product, packaging, parcel or an accompanying document | Needed where the manufacturer is outside the EU |
| Importer’s name or trademark, postal and electronic address | On the product or packaging | Extra labels must not cover the manufacturer’s details |
| Warnings and safety information | With the product | In a language the buyer easily understands, which each EU country sets |
The details go on the product itself where they can. If the product is too small, they can go on the packaging or an accompanying document.
What must an online listing show?
An offer for sale online has to show the same key facts. The product page needs:
- the manufacturer’s name and contact details;
- the EU responsible person’s details, if the manufacturer is outside the EU;
- a picture of the product, its type and any other identifier;
- warnings and safety information in the right language.
Marketplaces check these and ask for them when you upload a listing. If you sell on your own site, the same rules apply to your product pages.
Is CE marking enough?
No. CE marking shows that a product meets specific EU product rules, and it comes with its own requirements for manufacturer or importer details. The GPSR sits alongside it and covers what those rules do not. Many products need both, and a CE mark on the box does not name your EU responsible person for the GPSR. Our guide to importing from China to the EU covers CE marking and the other EU rules in one place.
What should you agree with the factory before production?
- Decide who the responsible person is
An EU importer or an authorised representative with a written mandate. Name them before you design the label.
- Ask for the technical documentation
Test reports, the product specification and any declaration of conformity. Check the model and test standard match your product.
- Write the label content
Manufacturer details, responsible person details, identifier and warnings, in each language you sell in.
- Approve a printed proof
Check every line on the proof against your list. Print only after you sign it off.
- Check the labels at inspection
Add the label content to the inspection checklist, so the inspector checks it on the finished goods.
What does a worked example look like?
Example, not legal advice: a UK brand sells a kitchen gadget made in China to customers in Germany and France through its own website.
| Item | What the brand does |
|---|---|
| Manufacturer | The factory’s name, address and email, as printed on the product |
| Responsible person | An EU authorised representative named by written mandate, with a postal and email address |
| Identifier | A batch number moulded into the product and printed on the box |
| Warnings | A short safety leaflet in German and in French, since each country sets its own language |
| Listing | The manufacturer and representative details and a product photo on the product page |
| Inspection | The label and leaflet are on the checklist for the pre-shipment inspection |
The brand then checks the rules for its product type, because the gadget may also fall under specific EU rules such as those for electrical goods.
How can CFS help?
We check that the label content and warnings appear on the proof and on the finished goods, as part of our quality control service. Our authorised representative service covers the EU representative role for many products, and we confirm the right arrangement for your product before you commit. If your packaging needs a redesign to make room for the labels, our team of eight in-house designers does that as part of a packaging order.
The bottom line
The GPSR asks for three things you can settle before production: a named responsible person in the EU, the right details on the product and in the listing, and technical documents someone has actually read. Sort them while the label is still a file, and the first order ships without a relabelling job. If you are not sure which route fits your product, send us the brief and we will tell you before you print.
Checked against Regulation (EU) 2023/988 and the European Commission’s GPSR FAQ and business guidelines, 6 November 2026. This guide is general information, not legal advice. Our guide to sourcing products from China covers the steps that come before this one.
Questions we get asked
Does the GPSR apply if I sell from the UK to customers in the EU?
Yes. The GPSR is EU law and applies to products offered to consumers in the EU, including online sales. A UK business with no EU company needs an EU responsible person for those products, such as an importer in the EU or an authorised representative.
Can my Chinese factory be the EU responsible person?
Only if it is established in the EU, and a factory in China is not. The factory can appoint an authorised representative in the EU by written mandate. That representative can then act as the responsible person for the product.
Is an EU address on the box enough to comply with the GPSR?
No. The address is one part. The product also needs an identifier such as a type, batch or serial number, the manufacturer's details, warnings and safety information in the right language, and technical documentation that the responsible person has checked.
Which language do the warnings need to be in?
Each EU country sets the language. Use the language of every country where you sell the product, so a product sold in Germany and France needs warnings in German and French.
Is the GPSR the same as CE marking?
No. CE marking shows a product meets specific EU product rules, such as those for toys or electrical goods. The GPSR is a safety net that covers products and risks those rules do not cover, so many products need to meet both.