EU GPSR for Appliance Sellers: The Responsible Person and What Must Appear on the Product

Most appliance buyers selling into the EU treat compliance as a CE question, and for the technical side that is broadly right. But since 13 December 2024 a second regime has applied alongside it: the General Product Safety Regulation, Regulation (EU) 2023/988, which replaced the older General Product Safety Directive.

The GPSR is not mainly about test reports. Its most consequential requirement is structural: a product can only be placed on the EU market if an economic operator established in the EU is responsible for it, and that operator’s details must appear on the product, its packaging or an accompanying document — and in every online offer. Buyers who treat compliance as a factory-side paperwork exercise discover this at the border.

This is a planning overview, not legal advice. The rules are detailed, they interact with product-specific legislation, and they change. Confirm the current position for your product and your sales route with a qualified adviser before you ship.

The requirement that catches non-EU sellers

A manufacturer outside the EU cannot place a product on the EU market until a company established in the EU has taken on the responsible-person role. That role is defined by reference to the market surveillance framework and carries specific duties, not just a name on a label.

Who can take the role

There is a defined order of precedence, and where you sit in it depends on how your goods reach the EU:

• The EU manufacturer, if the product is made inside the EU.
• The importer, if the product is made outside the EU and brought in by an EU-based importer.
• An authorised representative established in the EU, acting under a written mandate from the manufacturer — the usual route when there is no importer.
• A fulfilment service provider, in defined circumstances where none of the above exists.

The practical consequence is worth stating plainly: if you sell directly to EU consumers from stock held outside the EU, there is usually no importer in the chain, so you cannot rely on one. You need an authorised representative or another valid arrangement established in the EU before the first order ships, not after.

A second point is missed just as often: the importer can act as your responsible person, but only if it is willing and able to do the work. Naming a commercial partner who never actually imports the goods, or who has no access to your technical documentation, produces a label that looks compliant and a setup that fails when an authority asks a question.

What the responsible person actually has to do

1. Make sure the technical documentation exists, and provide it to authorities on request.
2. Inform the authorities where there is reason to believe the product presents a risk.
3. Cooperate on corrective action — withdrawal or recall where required.
4. Check periodically that the product matches its technical documentation and its labels.

These are operating duties with a workflow behind them. A responsible person who cannot reach your technical file, or who has no process for handling a complaint or an incident, is not performing the role.

What has to appear, and where

The operator’s name, registered trade name or registered trade mark, postal address and electronic address must be indicated on the product, on its packaging, on the parcel, or in an accompanying document — and in every online offer for the product. Purely digital labelling does not satisfy the physical requirement; a QR code can supplement it, not replace it.

Where CE and GPSR overlap, and where they do not

This is the part that produces the most confusion. Where another EU law already sets safety requirements for a product — the legislation behind CE marking, for instance — the GPSR only covers the risks that legislation leaves out. For those products, the general company duties largely fall away. But the rules on online offers and on accident reporting still apply.

For most household appliances that means the practical GPSR workload is narrower than the regulation looks, but it is not zero. The three things that reliably still matter are: the responsible person, the information in the online listing, and the route for reporting a dangerous product or an incident.

The corollary is the mistake to avoid: “we have CE, so GPSR does not apply to us” is not a safe reading. It is true that the technical requirements overlap; it is not true that the operator and listing requirements disappear.

The manufacturer duties that remain

• Risk assessment and technical documentation, describing the product, the characteristics relevant to safety, and how risks were eliminated or reduced — kept for the period the regulation requires, which is ten years after the product is placed on the market.
• Traceability: a type, batch or serial number that is visible and legible, or carried on the packaging where the product is too small.
• Manufacturer identification: name or registered trade mark, plus a postal and electronic address.
• Instructions in the language of the market, and the safety information that goes with the product.

What goes wrong in practice

• The responsible person is decided after the order is placed, so the first shipment has no valid arrangement.
• The label carries the manufacturer but not the EU operator, or carries an operator who never agreed to the role.
• The online listing omits the operator details, so a marketplace delists the product or an authority queries it.
• Technical documentation sits with the factory and the importer cannot obtain it when asked.
• Purely digital labelling is used where a physical label is required.
• Nobody owns accident reporting, so an incident has no route to the notification system.

What to settle before the first shipment

1. Map the sales route — importer-based, marketplace, or direct-to-consumer from outside the EU. The route determines who can be the responsible person.
2. Select the operator and get written acceptance of the role, with a named contact.
3. Put the operator details into the artwork for the label, packaging or accompanying document, and into the listing copy.
4. Confirm you can actually obtain the technical documentation, not merely that it exists.
5. Agree who reports incidents and how, before anything goes wrong.

How ApplianceChain helps

We are not a compliance adviser, we do not act as a responsible person, and we do not issue declarations. What we can do is the part that has to happen at the factory: check that the artwork includes the operator details your route requires, confirm that the technical documentation can actually be produced on request, and flag the information that is routinely missing from a supplier’s standard pack before it is printed.

The legal determination — which route applies to you, who should hold the role, and what your obligations are — belongs with you and your adviser. Our certification guide explains how market markings map to markets, and the certification overview covers the technical side.