GPSR · EPR · Roles
Responsible Person vs authorised representative: which EU contact do you need?
They are not the same appointment, and buying one does not cover the other. A GPSR Responsible Person covers product safety, and usually one can serve the whole EU. An EPR authorised representative handles registration, fees and reporting for packaging, electronics or batteries, and you generally need one in every member state you sell into. Cosmetics have a third Responsible Person of their own, under different law. Here is how to work out which ones apply to you.
The four roles people call the same thing
Vendors sell all of these under the word "representative", which is where the confusion starts. They come from four different pieces of law, with different scopes and different counts.
| Role | Legal basis | What it covers | How many |
|---|---|---|---|
| GPSR Responsible Person | Article 16, Regulation (EU) 2023/988 | Product safety, and the EU contact shown in your online offer | Usually one for the whole EU |
| Article 4 economic operator | Article 4, Regulation (EU) 2019/1020 | CE-marked categories: toys, electricals, PPE, machinery | One for the whole EU |
| EPR authorised representative | PPWR Article 45; WEEE Directive Article 17; Regulation (EU) 2023/1542 | Registration, fees and reporting for packaging, electronics, batteries | One per member state, often per waste stream |
| Cosmetics Responsible Person | Article 4, Regulation (EC) No 1223/2009 | Cosmetic product safety, the CPNP notification, the product information file | One for the whole EU, named on the label |
When each appointment became a requirement
The obligations stacked up rather than replacing each other
- 16 July 2021In force
Article 4 economic operator for CE-marked goods
No CE-marked product without an EU-established operator behind it.
- 13 December 2024In force
GPSR Responsible Person for all other consumer products
Extends the same idea to the non-harmonised world, and puts the details in the listing.
- 18 August 2025In force
Batteries authorised representative, per member state
- 12 August 2026Next up
PPWR packaging authorised representative, per member state
By written mandate, in each country where you first make packaging available.
Source: Regulation (EU) 2019/1020; GPSR (EU) 2023/988; Regulation (EU) 2023/1542; PPWR (EU) 2025/40.
| Date | What applies |
|---|---|
| 16 July 2021 | Article 4 economic operator for CE-marked goods |
| 13 December 2024 | GPSR Responsible Person for all other consumer products |
| 18 August 2025 | Batteries authorised representative, per member state |
| 12 August 2026 | PPWR packaging authorised representative, per member state |
What a GPSR Responsible Person actually does
The role exists so that an EU authority always has someone inside the Union to write to. Under Article 16 it can be filled by an EU-established manufacturer, an importer, an authorised representative holding a written mandate that covers these tasks, or, where none of those exist, a fulfilment service provider.
- Verifies that the declaration of conformity or technical documentation and the safety information exist, and keeps them available for authorities.
- Informs market surveillance authorities if there is reason to believe a product presents a risk.
- Cooperates on corrective action, including recalls.
- Appears by name, postal address and electronic address in your online offer under Article 19, and on the product, packaging or an accompanying document under Article 16(3).
One is normally enough
Nothing in GPSR requires a Responsible Person in each country. A single EU-established contact can cover all 27 member states, which is what makes this appointment fundamentally different from the EPR one below.
What an EPR authorised representative does
Completely different job. An EPR authorised representative takes on your producer obligations for waste: registering you in the national register, joining or paying a compliance scheme, and filing the volumes you put on that country's market each year. They handle money and filings, not product safety.
The count is the thing to understand. One per member state, and in practice often one per waste stream within that state. Packaging in Germany, packaging in France and electronics in Germany can easily be three separate arrangements. The legal bases arrived at different times: Article 17 of the WEEE Directive for electronics, the Batteries Regulation from 18 August 2025, and PPWR Article 45 for packaging from 12 August 2026.
The suspension proposal did not happen
In December 2025 the Commission proposed suspending the PPWR authorised representative rule until 2035 as part of its Environmental Omnibus. A large majority of member states objected and Council discontinued negotiations in June 2026. The 12 August 2026 date stands.
What this costs varies by country and by how much you actually ship. Real 2026 scheme rates are in how much EPR costs a small ecommerce seller.
The one nobody expects: cosmetics
If you sell cosmetics, the Cosmetics Regulation has required its own Responsible Person since long before GPSR existed. That person must be established in the EU, is named on the product label, notifies each product through the CPNP portal before it goes on sale, and holds the product information file including a safety assessment.
A GPSR Responsible Person is not a substitute for it, and appointing one does not get a cosmetic product notified. This is the mismatch we see most often in the category, and cosmetics were 36% of all EU Safety Gate alerts in 2025, the largest single category by some distance.
Can one company do both?
Commercially yes, legally they stay separate. Plenty of vendors offer a GPSR Responsible Person service and EPR representation as a bundle, and there is nothing wrong with that. What matters is that the mandate you sign actually covers the tasks you need. A mandate that appoints someone as your Responsible Person under GPSR does not register your packaging in Germany, and a German packaging representative does not become the contact in your product listings.
When you compare quotes, compare scope rather than price: which regulation, which member states, which waste streams, and whether the fees to the scheme are included or billed on.
Which do you need?
- Selling any physical consumer product to EU consumers, manufacturer outside the EU: a GPSR Responsible Person
- Selling CE-marked goods such as toys, electricals, PPE or machinery: an Article 4 economic operator, which the same appointment can usually satisfy
- Shipping goods in your own packaging to consumers in a country where you are not established: an EPR authorised representative in that country, from 12 August 2026 for packaging
- Selling electricals or batteries: WEEE and battery registration, with a representative per country
- Selling cosmetics: a Cosmetics Regulation Responsible Person and a CPNP notification per product
How Assuro helps
Assuro tracks which of these apply to your catalogue and your markets, flags the products missing a Responsible Person, and keeps the registration and reporting deadlines per country. We do not act as any of these representatives and we do not file on your behalf. We tell you which ones you need and when the next thing is due.
Frequently asked questions
Is a Responsible Person the same as an authorised representative?
Not quite. An authorised representative is a mandate relationship: someone appointed in writing to act for you. A GPSR Responsible Person is a role that has to be filled by someone established in the EU, and an authorised representative is one of the four ways to fill it. The confusion comes from EPR, where authorised representative means something different again: the entity carrying your waste registration and fees in one member state.
Do I need an authorised representative in every EU country?
For EPR, generally yes: one per member state you sell into, and often one per waste stream. For GPSR product safety, no. One EU-established Responsible Person can cover the whole Union.
Can my EU logistics provider or 3PL be my Responsible Person?
A fulfilment service provider can fill the role under Article 16, but only where no EU manufacturer, importer or authorised representative exists. It is the fallback in the list, not the first choice, and many 3PLs decline the liability. Get any such arrangement in writing.
Does one appointment cover both GPSR and PPWR?
Only if the mandate says so and the provider is set up in that member state for packaging. They are different obligations under different regulations. Ask which regulations and which countries a quote covers before assuming it is one service.
I sell cosmetics and already have an EU Responsible Person. Am I covered for GPSR?
For the safety aspects the Cosmetics Regulation covers, the cosmetics Responsible Person is the relevant role. The two regimes are not interchangeable, so check that your provider's mandate names the right regulation, and that your CPNP notifications are current.
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