Yunhe, Zhejiang · 0–3 wooden toys · MOQ from 10 pcs · per-model report status sales@babywoodentoys.com
BWT BabyWoodenToys

Compliance

GPSR and the EU responsible person

Core position: the responsible person must be established in the EU. We are not established in the EU, so we cannot hold that role for your products. What we can do is supply the documentation and label data the responsible person will ask for.

For the walkthrough version, see GPSR and the EU responsible person.

Requirements at a glance

RequirementDetailWho owns it
RegulationGeneral Product Safety Regulation (EU) 2023/988, applicable since 13 December 2024EU importer / responsible operator
EU-established responsible personRequired for products sold to EU consumers, including distance salesManufacturer or importer appoints
TraceabilityIdentify the product and the operators in the chainManufacturer and importer
Online listing informationManufacturer and responsible person details, product identification and warningsSeller / listing owner
Complaint handlingA channel for end users to report safety issues, and a response processResponsible operator
Incident and recall processRegister, notification and actionResponsible operator
DocumentationTechnical file and declaration available to authoritiesResponsible operator holds

Who can act as the responsible person

  1. The EU importer, when it places the product on the market under its own name.
  2. An authorised representative appointed in writing by the manufacturer, established in the EU.
  3. A fulfilment service provider established in the EU, where the arrangement meets the regulation's conditions.
  4. A specialist third-party responsible-person service.

An entity outside the EU cannot hold the role. A Chinese factory, trading company or export agent naming itself as the EU responsible person does not satisfy GPSR, whatever the invoice says.

What the role actually carries

  • Hold the technical documentation and the DoC, and provide them to authorities on request.
  • Cooperate with market surveillance authorities within the required timeframes.
  • Keep a register of complaints, incidents and recalls, and pass information through the chain.
  • Act on unsafe products: withdrawal, recall, consumer information, authority notification.
  • Verify that the product carries the required operator details, including the email address introduced with the 2025/2509 framework.

The role carries liability, which is why it is priced as a service. Confirm scope, price and response obligations directly with the provider.

Online listing requirements

GPSR makes the product page part of the compliance surface. A listing should show:

ItemWhy
Manufacturer name and postal addressIdentifies the party behind the product
EU responsible person name and addressThe contact authorities use
Product identification, including model and batch where relevantEnables traceability and targeted recall
Warnings and safety information in the market's languageRequired for toys, frequently missing
Age grading and applicable warningsUnder-3 products carry specific warnings
A contact channel for safety complaintsEnd users must be able to reach someone

A PDF linked in the footer does not satisfy this. The information belongs on the product page, in the fields the marketplace or the shop provides.

What we supply, and what stays with the buyer

ItemWe supplyBuyer does
Test reports with scope and editionsYesFiles with the responsible person
BOM and material declarationsYesSupports the technical file
Factory identity and production dataYesRecords in the technical file
Label data: operator names, addresses, warningsPartly — manufacturer sideAdds importer and RP details
Responsible person appointmentNoBuyer appoints an EU entity
Complaint handling and recall recordsNoResponsible operator

Common failure modes

  1. No EU entity in the chain. The listing is live, the product is in a warehouse, and nobody is the responsible person.
  2. Supplier named as responsible person. A non-EU entity cannot hold the role, so the file fails on its face.
  3. Listing fields empty. Marketplace compliance fields left blank because nobody owns the data.
  4. Warnings in the wrong language. English warnings on a listing targeting a non-English market.
  5. No complaint channel. The responsible person is named but unreachable.

FAQ

Q: Does an Amazon seller need a responsible person?

Yes. GPSR applies to distance sales, and the marketplace will require manufacturer and responsible person details on the listing.

Q: Can the factory be the responsible person?

No. The responsible person must be established in the EU. The factory can supply data but cannot hold the role.

Q: Is the EU importer automatically the responsible person?

The importer is an economic operator with its own obligations. Whether it is formally the responsible person depends on the arrangement, but it is the natural candidate for most ranges.

Q: What does a responsible person service cost?

It is usually an annual service line, priced per product or per range. Confirm directly with the provider; costs vary with the number of SKUs, languages and documents involved.

Related pages: EU 2025/2509 and the DPP and the guide to US tracking labels. For the data pack your RP will request, use the quote form.

This is a commercial explainer, not legal advice. Certification is model-specific and market-specific.

Tell us the model and the market

We confirm whether a report exists, or whether testing can be commissioned.

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