EU GPSR Compliance Guide 2026: How to Appoint a Responsible Person (RP) for Amazon Sellers

If you sell consumer products on Amazon Europe, AliExpress, TEMU, or Shopify to EU customers, the General Product Safety Regulation (GPSR) is not just another acronym to memorize—it is the single most consequential EU product safety law of this decade. Effective since December 13, 2024, and now in full enforcement throughout 2026, GPSR (Regulation (EU) 2023/988) has fundamentally reshaped how non-EU manufacturers access the European single market.

I have spoken to dozens of Amazon sellers in the past year, and the pattern is always the same: they receive a compliance notification email from Amazon Seller Central, panic-search for "cheap Responsible Person," and end up wasting weeks navigating conflicting advice. This guide is written to cut through the noise. Whether you sell kitchen gadgets, smart home devices, children's toys, or fitness accessories, by the end of this article you will know exactly what GPSR requires, how much it costs, and how to get compliant without overpaying.

Let us start with the most important concept: if your business is based outside the EU and you sell directly to EU consumers, you must appoint an EU Responsible Person. Period. There is no workaround, and using a fake address is a direct path to a suspended account.

1. GPSR vs. GPSD: What Changed and Why It Matters

To understand why GPSR compliance feels more burdensome than "old" EU product safety rules, you need to understand what came before it. The General Product Safety Directive (GPSD, 2001/95/EC) served as the baseline for consumer product safety in the EU for over two decades. But it was a directive—meaning each member state had to transpose it into national law, resulting in 27 slightly different implementations. More critically, it was written in an era before mass cross-border e-commerce and lacked enforcement mechanisms for non-EU sellers.

GPSR replaces GPSD as a regulation, which means it is directly applicable and identical across all 27 EU member states plus Norway, Iceland, and Liechtenstein (EEA). Below is a side-by-side comparison of the key changes:

The bottom line: GPSR closes the loophole that allowed non-EU sellers to flood European marketplaces with unverified products. Now, every foreign manufacturer must have a legal anchor inside the EU.

2. Who Needs an EU Responsible Person (RP)?

Under GPSR Article 16, an EU Responsible Person is required when a product is placed on the EU market and none of the following is established in the EU: the manufacturer, the importer, or an authorized representative. In plain English: if you manufacture in China (or any non-EU country) and sell directly to EU consumers online, you need an RP.

The RP's legal duties include:

• Keeping the Declaration of Conformity and technical documentation available for market surveillance authorities for 10 years.
• Cooperating with authorities on any corrective actions, including product recalls.
• Informing authorities immediately if a product presents a safety risk.
• Ensuring the product label includes the RP's name, registered trade name or trademark, and postal and electronic contact address.

It is important to note that Amazon FBA does not make Amazon your importer or RP. Amazon has been explicit about this: they are a logistics provider and marketplace, not a responsible economic operator under GPSR.

3. RP Service Provider Comparison: Obelis, CDG, and More

Choosing the right RP provider is the most consequential financial decision in your GPSR compliance journey. Prices vary wildly, and so does the quality of service. Below is a comparison of the most commonly used RP service providers as of 2026:

4. Required Documentation: Beyond the RP Appointment

Appointing an RP is only the first step. GPSR requires you to maintain a robust set of technical documentation. Here is the complete checklist of what you must prepare before your RP can begin representing you:

• Product Description and Identification: Clear product name, model number, SKU, and a unique identifier (such as GTIN or EAN).
• Manufacturer Details: Full legal name, registered address, and website URL of the non-EU manufacturer.
• General Product Safety Assessment: A documented risk analysis covering intended use, foreseeable misuse, hazards, and mitigation measures.
• Test Reports from Accredited Labs: ISO 17025-accredited test reports demonstrating compliance with applicable EU harmonized standards (e.g., EN 71 for toys, EN 60335 for household appliances).
• Declaration of Conformity (DoC): A signed statement declaring that the product meets all applicable EU safety requirements.
• User Manuals and Safety Instructions: In the official language(s) of the EU member state(s) where the product is sold.
• Incident Reporting Procedure: A documented process for handling product safety incidents and notifying authorities.
• Traceability Records: Batch or serial number tracking system enabling identification of affected units during a recall.

For products that also fall under specific harmonization legislation, additional documentation applies. For example, smart devices with wireless modules require CE-RED test reports. Products containing batteries must comply with the EU Battery Regulation (2023/1542) and WEEE Directive. Packaging must meet EPR packaging requirements in countries like Germany and France.

5. Step-by-Step: Uploading GPSR Info to Amazon Seller Central

Amazon has integrated GPSR compliance into Seller Central through the "Manage Your Compliance" (MYC) dashboard. Here is the exact workflow you should follow:

1. Navigate to MYC Dashboard: Log into Seller Central, go to Performance �?Account Health �?Manage Your Compliance. You will see a list of ASINs flagged for GPSR compliance.
2. Submit Responsible Person Information: For each affected ASIN (or in bulk via CSV upload), provide the RP's full legal name, physical EU street address (not a P.O. box), email address, and phone number.
3. Upload the Declaration of Conformity: Attach a PDF of your signed DoC. The DoC must reference the applicable GPSR regulation and list all harmonized standards applied.
4. Attach Product Documentation: Upload your user manuals in the relevant EU language(s). Amazon's system may require one file per language.
5. Verify and Submit: Amazon reviews the submission within 48�?2 hours. You will receive a confirmation notification when the ASIN is marked as compliant.
6. Monitor Compliance Status: Periodically revisit the MYC dashboard to ensure ongoing compliance, especially after updating product listings or adding new marketplaces.

6. Member State Enforcement Timeline and Penalties

Although GPSR became EU law on December 13, 2024, enforcement intensity varies by member state. The following timeline shows how different countries have ramped up enforcement in 2025-2026:

• Germany (Marktüberwachung): Active enforcement began Q1 2025. Known for aggressive customs checks and marketplace sweeps. Penalties can reach EUR 600,000 per violation.
• France (DGCCRF): Enforcement began Q2 2025. DGCCRF conducts online surveillance of marketplace listings and issues formal notices with 30-day compliance windows.
• Netherlands (NVWA): Enforcing since Q3 2025. Focus on children's products and electronics.
• Italy and Spain: Phased enforcement throughout 2025. Less aggressive than Germany but increasing in 2026.
• Nordic Countries: Sweden and Denmark began full enforcement in Q4 2025, with a reputation for thorough documentation reviews.
• Eastern EU (Poland, Czech Republic, Romania): Enforcement ramping up in 2026. Often under-estimated by sellers.

7. Fee and Time Estimate

Here is a realistic breakdown of the costs and time required to achieve full GPSR compliance for a typical Amazon seller with 5 product SKUs:

8. Common Mistakes and How to Avoid Them

After reviewing hundreds of seller compliance cases, these are the most frequent errors—and how to sidestep them:

1. Using a Virtual Office as RP Address: Authorities require a physical location where the RP can be reached in person. Virtual offices, coworking space mailboxes, and P.O. boxes are rejected upon audit.
2. Signing an RP Mandate Without Reading It: Some low-cost RP providers include clauses that limit their liability to the point of making the appointment legally ineffective. Always have a lawyer review the mandate before signing.
3. Assuming Existing CE Marking Covers GPSR: CE marking addresses product-specific directives (like RED, EMC, LVD). GPSR addresses general product safety. You need both—they are separate compliance obligations.
4. Uploading Incomplete Documentation to Amazon: Amazon's MYC system requires separately labeled files. Submitting a single PDF with everything inside will often be rejected. Follow the dashboard prompts precisely.
5. Ignoring Language Requirements: A user manual in English does not satisfy the legal requirement in Germany (German required), France (French), or Italy (Italian). You must provide manuals in the official language(s) of each country where you sell.
6. Delaying the RP Appointment: Many sellers wait for Amazon's compliance deadline email before starting. By then, RP providers are overloaded and turnaround times balloon from days to weeks.

David Chen

EU Regulatory Compliance Specialist with 8+ years of experience helping cross-border e-commerce sellers navigate European product safety laws. Former compliance consultant for Amazon Global Selling program.