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Regulatory Compliance Analyst | EU/UK Product Compliance & Risk Mitigation
Regulatory Compliance Analyst at Euverify with experience in EU and UK product safety requirements. Focused on risk assessments, technical file preparation, and regulatory mapping across diverse products. Brings a creative edge to compliance work, supported by a background in AI-driven research and analysis.
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When Fulfilment Providers Become the Responsible Person Under GPSR
If you run a fulfilment centre, 3PL warehouse, dropshipping operation, or Amazon FBA logistics service, you probably do not see yourself as the legal guardian of your clients’ product safety. You store, pick, pack, and ship. That should be the whole story.
But the General Product Safety Regulation (EU) 2023/988 changed everything. Many fulfilment providers now discover, often too late, that they have been automatically assigned the role of Responsible Person under GPSR. This comes with serious legal duties they never expected to shoulder.
It is one of the biggest hidden compliance risks in today’s ecommerce supply chains. And once fulfilment businesses realise what the law requires, the panic is real. Within days they start looking for expert support because this is not something they can handle alone.
Let’s break down how this happens and what you can do about it.
Why GPSR Creates a New Compliance Shock for Fulfilment Providers
The GPSR is the EU’s updated rulebook for consumer product safety. It applies to all non-food consumer goods unless a sector-specific law covers them. It took effect in December 2024.
Fulfilment providers are specifically identified as economic operators in the supply chain. According to the official EU Guidelines, a fulfilment service provider is any business offering at least two services such as warehousing, packaging, addressing, or dispatching without owning the products (European Commission, 2025, p. 35)
This means that logistics companies are no longer “just the warehouse”. They are technically a regulated actor.
The consequences become serious when the seller has no other EU-based representative.
Which Fulfilment Providers Are Affected by GPSR?
The following types of fulfilment businesses are directly impacted by the GPSR requirement for an EU Responsible Person:
- Third-party logistics providers (3PLs)
- Ecommerce fulfilment centres
- Amazon FBA fulfilment locations and marketplace-operated warehouses
- Dropshipping fulfilment partners
- Pick-and-pack warehouses
- Cross-border ecommerce hubs storing EU-bound products
- Print-on-demand fulfilment centres
- Last-mile distribution centres that store inventory before dispatch
All these providers can become economic operators under the GPSR. When there is no manufacturer, importer, or authorised representative in the EU, these fulfilment actors become the Responsible Person by default.
For many of them, this comes as a surprise.
How Fulfilment Providers Become the Responsible Person Without Realising It
Under the GPSR, every product sold to EU consumers must have a clearly identified Responsible Person. Someone located within the EU must take charge of key safety tasks.
The regulation lists the order of priority for who becomes the Responsible Person:
- The EU-based manufacturer
- The EU-based importer
- An authorised representative
- If none of the above exist, the fulfilment service provider becomes the Responsible Person by default
This is spelled out clearly in the GPSR Guidelines: a fulfilment service provider becomes the responsible person “if no other economic operator is established in the EU” (European Commission, 2025, p. 36)
This is exactly how thousands of fulfilment providers end up with legal duties they never agreed to.
Common real-world scenarios
These situations trigger the automatic Responsible Person assignment almost every week:
- A Chinese or US seller ships goods directly to an EU warehouse
• A dropshipper uses an EU 3PL for last-mile delivery
• An Amazon FBA merchant stores inventory in an EU fulfilment centre with no importer
• A marketplace seller lists products without naming an EU Responsible Person
In all these cases, the warehouse becomes the default safety contact.
What Being the Responsible Person Means for a Fulfilment Provider
This is where things get complicated. The Responsible Person role comes with heavy obligations, similar to those of a manufacturer or importer.
According to the EU Guidelines, the Responsible Person must carry out the tasks listed in Article 4 of Regulation (EU) 2019/1020 and Article 16 of the GPSR (European Commission, 2025, pp. 36–39)
Here is what that means.
1. Holding and providing the technical documentation
The Responsible Person must verify that the manufacturer has created technical documentation and must supply it to authorities on request. This includes risk assessments, test reports, design details, and safety evidence.
2. Checking that safety information and labels are correct
Before the product is shipped, the Responsible Person must make sure all required markings, batch numbers, and safety instructions are present and compliant. This is not a quick visual check. It is a legal obligation that requires expertise.
3. Monitoring product safety and reporting risks
If the Responsible Person believes a product presents a risk, they must report it to market surveillance authorities through the Safety Business Gateway (European Commission, 2025, pp. 37–38)
4. Managing recalls and corrective actions
If a product is unsafe, the Responsible Person must help coordinate:
- recalls
• withdrawals
• consumer notifications
• destruction of unsafe stock
• traceability information
• remedies for consumers (repair, replacement, refund)
This is one of the most time-consuming and complex compliance tasks. The official guidelines lay out strict rules for recall notices, consumer communication, and remedies (European Commission, 2025, pp. 43–47)
5. Keeping complaints and accident records
The Responsible Person must maintain complaint logs, investigate safety issues, and notify authorities of any accidents involving the products.
6. Cooperating with market surveillance authorities
If authorities request documents, the Responsible Person must provide them quickly. They may also be asked to assist in investigations.
For a fulfilment business, this is far beyond normal logistics work.
Why Fulfilment Providers Panic When They Learn This
Fulfilment companies panic not because of the paperwork but because of the liability.
They face fines and legal exposure
EU Member States can impose fines for violations of the GPSR (European Commission, 2025, p. 4)
They are unprepared for safety investigations
Most fulfilment centres have no:
- compliance staff
• product safety procedures
• ability to review technical files
• systems for accident reporting
• capacity to manage recalls
Yet the law expects them to comply fully.
Their business model collapses if they refuse inventory
Imagine telling a top ecommerce client:
“We cannot store your goods until you prove full regulatory compliance.”Many fulfilment companies feel trapped.
- compliance staff
How Fulfilment Providers Can Protect Themselves Today
There are practical steps that reduce the risk of being forced into this role.
1. Update your contracts
Make it mandatory for clients to appoint their own EU Responsible Person. This clause alone removes the automatic assignment risk.
2. Require technical documentation before stock acceptance
This step ensures your warehouse never ends up responsible for a non-compliant product.
3. Train your staff on basic GPSR checks
Your team must know how to identify missing labels, traceability markers, or incomplete information.
4. Work with a third-party Responsible Person service
This is the safest and fastest solution. A compliance provider can act as the official Responsible Person, manage the technical files, handle risk assessments, assist in recalls, and communicate with authorities.
It removes the liability from your fulfilment business and keeps your clients compliant.
Final Takeaway
The GPSR did not change what fulfilment providers do. It changed how the law sees them.
If no importer or authorised representative exists, the fulfilment centre becomes the Responsible Person by default. That role comes with responsibilities you cannot ignore and cannot simply hand back. It involves safety documentation, recall coordination, accident reporting, and ongoing cooperation with authorities. Most fulfilment businesses are not built for that level of regulatory work, and the risks can be significant.
The good news is that you do not need to take on this role alone. With the right processes and a trusted compliance partner, fulfilment providers can protect themselves, support their clients safely, and avoid being forced into a position they never intended to fill.
Euverify acts as an EU and UK Authorised Representative and Responsible Person for sellers across a wide range of product categories. This removes the liability from fulfilment centres and 3PLs, keeps their clients compliant, and ensures that products can move smoothly through the supply chain without unexpected legal exposure.
If your warehouse or fulfilment business wants to stay protected under the GPSR, partnering with Euverify is the safest and most efficient way forward.
References
European Commission (2025). Guidelines on the Application of the EU General Product Safety Legislative Framework by Businesses. C(2025) 7699 final.
Regulation (EU) 2023/988 of the European Parliament and of the Council on General Product Safety.
Regulation (EU) 2019/1020 on Market Surveillance and Compliance of Products.
European Commission. Safety Gate Portal. https://ec.europa.eu/safety-gate
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