Which GPSR Authorised Representative Should You Choose?
| Direct answer: You only need to pay for a GPSR Authorised Representative (AR) if you don’t already have an EU or UK-based manufacturer entity, importer, or fulfilment provider willing to take on the Responsible Person role. If you do need one, look at three things: does it cover both the EU and UK (most non-EU sellers need both), does the pricing fit your catalogue size, and can the provider actually carry out the Article 16 duties rather than just hold a signed mandate. For most small and mid-sized consumer brands, the practical answer is a platform-based provider charging somewhere between £30 and £170 a month depending on product count, instead of a flat per-product AR fee. |
Do you actually need to pay for a GPSR authorised representative?
Under the General Product Safety Regulation (EU) 2023/988, every consumer product placed on the EU market needs a Responsible Person established in the EU. This comes from Article 16, alongside Article 4 of the Market Surveillance Regulation (EU) 2019/1020, and it’s been mandatory since 13 December 2024. It applies whether or not your product also needs CE marking.
There’s a hierarchy for who takes on this role. Whichever entity below is first to be established in the EU becomes the Responsible Person:
1. The manufacturer, if it’s EU-based
2. An Authorised Representative, if the manufacturer has mandated one
3. The importer, if there’s no EU manufacturer or AR
4. The fulfilment service provider, as a last resort, if none of the above exist
So before comparing providers, check whether you already have an EU importer or distributor who’ll take on this role. If you do, you might not need to pay for a dedicated AR at all. If you sell through Amazon FBA or a third-party logistics provider, ask them directly whether they’ll accept the Responsible Person role. Most standard logistics providers say no, which puts the obligation back on you as the manufacturer.
If none of those apply, you need to appoint an AR.
What GPSR actually requires from your representative
Most comparison articles skip this part, but it’s the actual checklist to judge any provider against. Under Article 16(2), the Responsible Person has to:
• Verify the manufacturer’s technical documentation exists and covers the product description, risk analysis, and risk mitigation
• Verify the product carries proper identification (type, batch, or serial number)
• Verify contact details — name, postal address, and email — appear on the product, its packaging, or an accompanying document
• Hold the technical documentation for 10 years after the product’s last placement on the market
• Carry out sample testing and investigate complaints
• Report dangerous products to the relevant market surveillance authority immediately
• Cooperate with authorities and keep the rest of the supply chain informed of safety issues
A provider that just gives you “an EU address for your listing” isn’t meeting these obligations. The address is something that comes with the appointment. It isn’t the service itself.
How to choose a GPSR authorised representative: match the provider to your situation
| Your situation | What to look for | What to avoid |
| Small catalogue (under 50 SKUs), general consumer goods, no EU presence | A platform that bundles AR appointment, DoC generation, and document storage into a flat monthly fee | Per-product AR fees that scale badly as you add SKUs |
| Selling in both the EU and GB | A provider covering both EU and UK representation — most non-EU sellers need both | A provider that only covers one region and doesn’t flag that you likely need the other |
| Electronics, toys, or other CE-marked categories | A provider that can also act as Responsible Person under MSR Article 4, not just GPSR Article 16 | A provider that only understands GPSR and can’t speak to sector-specific obligations |
| Amazon FBA sellers | A provider whose mandate explicitly covers marketplace listing requirements | Assuming your fulfilment provider will silently take on the RP role — most refuse it |
Whatever type of provider you pick, ask to see the written mandate before signing up. It should spell out the tasks being delegated, which products or categories are covered, how long it runs and how to end it, and whether the AR is also taking on the Responsible Person role under Article 16 and MSR Article 4. If a provider can’t show you this upfront, treat that as a warning sign.
Where Euverify fits
Euverify works as a subscription platform rather than charging a separate AR fee. GPSR representation comes bundled into the plan instead of being sold on its own, which changes how the cost comparison works.
| Plan | Products | Monthly | Annual (eff. monthly) | Rep coverage |
| Starter | Up to 5 | £39 | £32 | EU or UK (+£200/yr for the other) |
| Growth | Up to 50 | £69 | £57 | EU or UK (+£200/yr for the other) |
| Scale | Up to 100 | £119 | £99 | Both EU and UK |
| Pro | Up to 500 | £169 | £140 | Both EU and UK |
Every plan includes AR appointment within 24 hours, EU/UKCA Declaration of Conformity generation, pre-filled risk assessment templates, 10-year compliant document storage, and marketplace integration support for Amazon, Etsy, Shopify, and eBay. There’s a 14-day free trial on all of them, and GPSR products don’t cost extra on top of the subscription. If you also sell cosmetics or medical devices, the product quota is shared across all three categories, but cosmetics and medical device compliance are separate service lines with their own fees on top of the subscription — cosmetics starts at £150 per product for notification-only work, and medical devices are priced as annual bundles starting around £900.
This setup works well if you want EU and UK coverage from one place and want the DoC generation and document storage handled inside the same platform, rather than stitched together from separate vendors. It makes less sense if you’re a single-SKU brand chasing the lowest possible one-off cost and don’t need any of the platform tooling.
Red flags to watch for a GPSR authorised representative, regardless of who you choose
• No written mandate before you sign up. This is a legal requirement, not something to sort out later.
• No mention of sample testing or complaint handling. These are Article 16 obligations. If a provider doesn’t bring them up, they may not actually be set up to do them.
• CE marking on a GPSR-only product. If your product isn’t covered by a harmonisation directive, it shouldn’t carry a CE mark at all. A provider that misses this is creating a compliance problem, not solving one.
• Vague answers on document retention. Technical documentation and the DoC need to be retrievable for 10 years after the product’s last sale, so ask exactly where and how they’re stored.
• No mention of Northern Ireland. NI follows EU rules under the Windsor Framework, even though it’s part of the UK. A provider that treats the “UK” as a single market might be missing this distinction.
Frequently Asked Questions
Legally, they’re two separate requirements. An EU Authorised Representative covers your EU market obligations, and a UK Authorised Representative covers Great Britain. One provider can hold both mandates though, so you don’t necessarily need two separate companies. Most sellers shipping to both markets need both types of representation, just not always from different providers.
An Authorised Representative is a role a manufacturer chooses to set up: they sign a written mandate appointing someone in the EU to act on their behalf. A Responsible Person is a role that has to exist for every product, whether or not an AR is involved. An AR often ends up being the Responsible Person, but the Responsible Person could just as easily be an EU-based manufacturer, an importer, or a fulfilment provider if none of the others are established in the EU. In practice, most non-EU sellers appoint an AR specifically so that AR can take on the Responsible Person role.
It depends on the provider, but same-day to 24-hour appointment is realistic once you’ve handed over your business and product details. That’s because the mandate is a written agreement between you and the AR, not something that has to go through a government registration process.
Since 13 December 2024, placing a product on the EU market without a Responsible Person is a GPSR violation. That can mean the product gets pulled from marketplaces, fines from national authorities, or a Safety Gate alert. Amazon and other marketplaces are required to check for this information, and they will delist products that don’t have it.
Only as a last resort in the legal hierarchy, and in practice most fulfilment providers won’t take on that liability. Unless you’ve got it confirmed in writing from them, plan on appointing your own AR..
GPSR excludes food, animal feed, medicinal products, living plants and animals, products of animal origin tied to their health, plant protection products, and aviation products, since these are covered by their own EU rules. Antiques are excluded too, along with products sent for repair or reconditioning before use, as long as the supplier makes that clear to whoever receives them. Almost everything else sold to consumers, including used and reconditioned products that go back on the market, falls under GPSR.
Yes, in most cases. GPSR specifically covers used products, repaired products, and reconditioned products once they re-enter the supply chain. The exemption only applies to items sent for repair or reconditioning before they’re used, and only if the supplier clearly tells the buyer that’s what’s happening. A secondhand product being resold as-is doesn’t get that exemption.
No. An Authorised Representative has to actually carry out the Article 16 duties: checking your technical documentation, holding it for 10 years, responding to market surveillance authorities, and reporting risks. A mailbox or virtual office address can put a name and address on your packaging, but it can’t do any of that. If a provider is only offering an address with no mention of these tasks, it isn’t a real AR service.
Most providers ask for your business registration details, a product description for each product or product family, and whatever technical documentation already exists, including risk assessments, test reports, and your Declaration of Conformity if you have one. If you don’t have a risk assessment yet, many platform-based providers can generate one from a template as part of onboarding, which is usually faster than pulling one together yourself.
Most providers ask for your business registration details, a product description for each product or product family, and whatever technical documentation already exists, including risk assessments, test reports, and your Declaration of Conformity if you have one. If you don’t have a risk assessment yet, many platform-based providers can generate one from a template as part of onboarding, which is usually faster than pulling one together yourself.
