What GPSR Article 16 requires
Regulation (EU) 2023/988 (GPSR) applies to all non-food consumer products sold in the EU, whether online or in a physical shop. Article 16 states that a product may only be placed on the EU market if an economic operator established in the Union is responsible for it. For a Chinese brand selling to EU consumers, that operator is normally an Authorised Representativeappointed in writing — the Responsible Person on the label.
Who counts as a Responsible Person
In order of priority under Article 16(2), the Responsible Person can be:
- The manufacturer, if established in the EU.
- The importer, if the manufacturer is outside the EU.
- An Authorised Representative established in the EU, appointed in writing by the manufacturer (Article 10 of Regulation 2019/1020 — the standard route for Chinese brands).
- A fulfilment service provider established in the EU, only when none of the above exist.
What has to be printed on the product
Article 19 requires that the Responsible Person's name, registered trade name or trademark, postal address and email appear on the product itself or, where that is not possible, on the packaging or an accompanying document. Marketplaces routinely audit this — a missing or wrong address on the label is one of the top delisting triggers in 2025 and 2026.
Responsible Person vs Authorised Representative
The Responsible Person is the outcome Article 16 requires. The Authorised Representative is the most common way a non-EU seller achieves that outcome. In practice, for almost every Chinese brand selling to EU consumers, the two are the same person, signed via one written mandate. Euranchor provides both under a single contract.
Common mistakes we see
- Buying a €199 EU address with no client vetting — a single problem tenant on that shared address damages every seller who shares it.
- Confusing the GPSR Responsible Person with the WEEE / battery / packaging EPR representative. They are different roles with different registers.
- Printing only the manufacturer's China address on the packaging. The Responsible Person's EU details must also be clearly visible.
- Assuming Article 16 does not apply to your product because you also sell in the UK or Switzerland. GPSR applies independently to any unit placed on the EU market.
How to appoint an EU Responsible Person this week
A properly documented appointment takes 24 to 48 hours from signature to the label update your marketplace needs. The minimum working checklist:
- Identify each product category (GPSR, and where relevant CE, LVD, RED, EMC).
- Sign a written mandate with an EU-established Authorised Representative.
- Update product artwork and packaging with the Responsible Person's EU name, address and email.
- Update your marketplace back office (Amazon "Compliance Reference", bol.com Responsible Person block, etc.).
- Hand over the technical file / DoC to the Responsible Person for 10-year archival.
Euranchor takes on all five steps under one contract, from our office in Leuven, with Chinese-language account management. Start with the free compliance check and we will tell you honestly whether you actually need the full service — or whether a single €500 file review is enough.