Who Is the EU Responsible Person and Why Amazon Sellers Need One

Who Is the EU Responsible Person and Why Amazon Sellers Need One

Entering the European Amazon marketplace means more than just translating your listings — it often requires designating an EU Responsible Person (RP).

For most product categories, this isn’t optional. Without a RP, your goods may be blocked at customs, delisted by Amazon, or even trigger legal penalties.

This article explains what an EU Responsible Person is, when you need one, and how Minefield Navigator helps you appoint one easily and compliantly.

What Is an EU Responsible Person?

The EU Responsible Person (RP) is a legal entity or individual based in the European Union who acts as the formal representative of your product.

This person is responsible for:

  • Ensuring your product complies with all relevant EU regulations
  • Keeping technical documentation (like the Declaration of Conformity) ready for authorities
  • Cooperating with market surveillance authorities if needed
  • Acting as the contact point for regulatory communication

Think of them as your compliance gatekeeper inside the EU.

When Do You Need an RP?

You must appoint an EU Responsible Person if:

  • You are not established in the EU, and
  • You sell products that are subject to GPSR (the vast majority of products) or other specific EU product safety laws

GPSR is a general rule applicable to most products Amazon sellers would sell, with the exception of food and a few other uncommon categories (e.g. aircraft parts).

Common product categories that require an RP:

  • Cosmetics – Products like skincare, perfumes, and makeup require a Responsible Person in the EU to ensure safety and maintain compliance documents (Regulation (EC) No 1223/2009).
  • Toys – Non-EU manufacturers selling toys in Europe must appoint an EU representative responsible for compliance and safety records (Directive 2009/48/EC).
  • Electronics (CE-marked) – All electronic products need an EU representative to handle technical files and communication with authorities (Regulation (EU) 2019/1020).
  • Medical devices – Medical products typically require an EU-based authorised representative to ensure legal compliance (Regulation (EU) 2017/745).
  • Personal protective equipment (PPE) – PPE items, like masks or gloves, often require an EU representative to manage regulatory obligations (Regulation (EU) 2016/425).

For many products — especially cosmetics and toys — the Responsible Person’s name, address and contact info must also appear on the product label or packaging. Since GPSR entered force, that includes an email. Amazon often checks this detail during compliance reviews.

Under Regulation (EU) 2019/1020, a product cannot be placed on the EU market unless there’s an economic operator established in the EU — which can be a manufacturer, importer, or an authorised representative (Responsible Person). The RP must be formally appointed in writing and is responsible for maintaining technical documentation and cooperating with market surveillance authorities.

Example: If you’re a U.S.-based seller shipping toys to Germany, you need an EU RP listed on your packaging before your products can legally enter the market.

Why Amazon Cares

Amazon actively enforces product compliance and the following information is entered into Seller Central:

  • Details of theirWho their EU Responsible Person, including name, address, and email
  • GPSR fact sheet or product pictures

Failure to comply can result in product delistings or permanent account suspension.

What About the UK?

Since Brexit, the UK no longer accepts EU RPs. If you sell to the UK and fall under the same categories, you will need a separate UK Responsible Person based in the United Kingdom. One exception is that EU GPSR rules apply, so you only need to worry about UK Responsible Person for categories of goods that are explicitly regulated.

How Minefield Navigator Helps

Minefield Navigator simplifies RP management by:

  • Acting as your EU-based Responsible Persons
  • Generating compliant label templates that include RP details
  • Keeping your RP information up to date across markets and SKUs
  • Alerting you to changing requirements in EU and UK laws

No more spreadsheets, guesswork, or outdated documentation.

Conclusion – Don’t Risk It, Get It Right

An EU Responsible Person isn’t just a bureaucratic formality — it’s a legal requirement and a critical part of staying compliant on Amazon EU.

Without one, your products may never leave customs or be taken down from Amazon overnight.

Minefield Navigator ensures you always have a compliant RP on file — and the right documentation ready when regulators come knocking.

Legal Resources:

• Regulation (EU) 2019/1020 (Market Surveillance)

• Directive 2009/48/EC (Toys)

• Regulation (EC) 1223/2009 (Cosmetics)

• Directive 2014/35/EU (Electronics)

• Regulation (EU) 2017/745 (Medical Devices)

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