GPSR Responsible Person for Toy Importers

Since 13 December 2024, the General Product Safety Regulation (EU) 2023/988 has applied to consumer products sold in the EU, wooden baby toys included. For non-EU suppliers and the importers buying from them, the operational change is simple to state and expensive to ignore: there must be a responsible person established in the EU, and their details must be visible on the listing and on the product.

This guide covers who can be the responsible person, what the role actually carries, and what a Chinese supplier of wooden baby toys can provide to support it.

What GPSR changed for toys

GPSR is a general safety regulation that sits alongside the toy-specific rules. It applies to distance sales, which means Amazon, Etsy, your own Shopify store and any EU marketplace. It requires traceability, risk management, a way to receive and act on safety complaints, and — the part that stops shipments — an EU-established economic operator who can be held accountable.

The toy legislation already requires importer details. GPSR widens that to the full distance-selling chain and makes the online listing part of the compliance surface.

Who can act as the EU responsible person

The responsible person must be established in the EU. In practice the role can be filled by:

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

What cannot happen: a Chinese factory, trading company or export agent naming itself as the responsible person. An entity outside the EU cannot hold the role, and a supplier promising "we will be your EU responsible person" is a warning sign rather than a solution.

What the responsible person must actually do

The role is not a mailbox. It carries obligations:

Hold the technical documentation and the declaration of conformity, and make them available to authorities on request.
Cooperate with market surveillance authorities and respond to requests in the required timeframe.
Maintain a register of complaints, incidents and recalls, and pass information up the chain.
Act if a product is unsafe: withdraw, recall, or inform consumers and authorities.
Verify that the product carries the importer's name, postal address and — under the 2025/2509 framework arriving by 2030 — an email address.

Because the role carries real liability, most EU importers either take it on themselves or use a specialist. Budget it as an annual service line, and confirm pricing with the provider rather than estimating from a blog.

What must appear on an online listing

GPSR makes the product page part of the safety file. The listing should show:

Item	Why it matters
Manufacturer name and postal address	Identifies who stands behind the product
EU responsible person name and address	The contact authorities will use
Product identification: model, batch or serial where relevant	Enables traceability and recall
Warnings and safety information in the language of the market	Required for toys, and frequently missing
Age grading and any applicable warnings	Under-3 products carry specific warnings
Contact channel for safety complaints	End users must be able to reach someone

If you sell on Amazon, the marketplace's compliance fields are the visible version of these obligations. If you sell on your own site, the product page is the listing, and a PDF link does not satisfy it.

The label data your responsible person will ask for

Before an RP will put its name on your product, it wants to know what it is taking on. Expect a request for:

Product name, model, SKU and age grade.
Manufacturer name and full address, plus production site.
Test reports and their scope: EN 71 parts, editions, tested materials.
Declaration of Conformity details.
Packaging and label artwork, including warning text in the target language.
Component list, including any battery, magnet, textile or silicone part.
Complaint and incident history for the model, if any.

A supplier that can answer that list in one file is easier to onboard than one that sends twelve emails. This is exactly the data pack we prepare per model.

What we can and cannot do

We supply the manufacturing and testing data your responsible person needs: reports, bills of materials, factory identity, label texts and translations in progress. We cannot act as your EU responsible person, because we are not established in the EU. Our role is documentation, not representation.

That boundary is worth stating plainly, because "we handle EU compliance" is a common and misleading sales line. Representation requires an EU legal entity. Documentation does not.

FAQ

Q: Do we need a responsible person if we sell only through Amazon?

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

Q: Can our Chinese supplier be the responsible person?

No. The responsible person must be established in the EU. Your supplier can supply the data; it cannot hold the role.

Q: Is the importer automatically the responsible person?

The EU importer is an economic operator and carries importer obligations. Whether it is formally the responsible person depends on the arrangement, but for practical purposes the importer is the natural candidate.

Q: What happens if we do not have one?

Import into the EU can be refused, and marketplaces can remove the listing. The exposure is operational first, legal second.

For the market reference page, see EU GPSR responsible person. For the labelling detail that feeds the listing, read label data for EU importers. If you are preparing an EU launch, the EN 71 guide covers the testing side; ask about label data for a model through the quote form.

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