A trading name of A Star Supply · ContactA trading name of A Star Supply · ContactA consumer product cannot be sold into the EU unless a business established in the EU is responsible for it. Here is who that can be, what they must do, and where their details go, taken from the regulation and official guidance. Instilus is not a Responsible Person and does not act as one.
▶ Watch: Do I Need an EU Responsible Person? GPSR Explained for Online Sellers (2026)
Article 16(1) of Regulation (EU) 2023/988 says a product covered by the regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020 for that product. The regulation calls this operator the "responsible person" (Articles 19 and 20).
Recital 39 explains why: direct online selling by businesses established outside the EU makes it hard for authorities to act, so the rule already used for CE-marked goods under Regulation 2019/1020 was extended to ordinary consumer products, giving authorities someone in the EU to deal with.
Having a Responsible Person does not move the manufacturer's own duties onto them. Article 16(2) applies "without prejudice to any obligations of economic operators" under the regulation.
Instilus is not a Responsible Person, is not established in the EU, and does not provide or arrange the role. You appoint or identify your Responsible Person yourself.
Article 16(1) applies Article 4(2) of Regulation 2019/1020, which allows four kinds of economic operator:
On the product: the Responsible Person's name, registered trade name or registered trade mark, and contact details including the postal and electronic address, on the product or on its packaging, the parcel or an accompanying document (Article 16(3)).
In every online or distance-sale offer: where the manufacturer is not established in the EU, the name, postal and electronic address of the Responsible Person (Article 19(b)), alongside the manufacturer's details, product identification with a picture, and any warnings or safety information.
The European Commission's 2025 guidelines explain that an electronic address can be an email address or a dedicated section of a website that lets consumers contact the business directly, and that a website as such is not enough if it does not allow direct communication.
The UK government's guidance on the regulation in Northern Ireland says that "established" means having a presence in NI or the EU, and cannot simply be, for example, a PO Box address. For a business it can be a registered office, headquarters or permanent place of business; for an individual, the place where they are resident.
The European Commission's 2021 guidelines on Article 4 of Regulation 2019/1020 add that authorities can require corrective action and impose penalties where the operator's details are missing, and the same applies where they are false, for example where the address does not exist or no such operator exists at it.
The test is whether the business is actually present in the EU (or, for Northern Ireland sales, in NI), not whether it has an EU postal address.
The regulation has applied to goods placed on the Northern Ireland market since 13 December 2024. UK government guidance says the responsible economic operator for those goods can be established in either Northern Ireland or the EU, and that a single operator can cover supply into both, whichever of the two it is established in.
A business established only in England, Scotland or Wales is not established in the EU. For EU sales, Article 16(1) therefore needs someone else from the list above: an EU importer, an authorised representative or, where none exists, an EU fulfilment service provider.
Amazon's Responsible Person fields are not described here, because we could not read them on a public Amazon help page.
A manufacturer established in the EU; an importer where the manufacturer is outside the EU; an authorised representative with a written mandate from the manufacturer; or, where none of those is established in the EU, an EU fulfilment service provider for the products it handles (Article 16(1) of Regulation 2023/988 and Article 4(2) of Regulation 2019/1020).
Not for EU sales unless it is established in the EU, because Article 16(1) requires an operator established in the Union. For goods placed on the Northern Ireland market, UK government guidance says an operator established in Northern Ireland can act.
No. UK government guidance says "established" means having a presence in NI or the EU and cannot simply be a PO Box address.
Yes, where the manufacturer is not established in the EU. Article 19(b) requires the Responsible Person's name, postal and electronic address in the online offer.
No. Article 16(2) applies without prejudice to the obligations of other economic operators, so the manufacturer keeps its own duties, including the risk analysis and technical documentation.
No. Instilus is not established in the EU and does not act as, provide or arrange a Responsible Person. It prepares documentation from information you supply.
Instilus organises the documents you already have into a GPSR evidence pack. Take the free eligibility check.
One email with the checklist, the label generator, the templates and the example pack. No account, and nothing else is sent unless you ask.