Who qualifies
Four possible roles
An EU-established manufacturer, an authorised representative appointed in writing, the importer, or a fulfilment service provider. All four must be established in the Union.
Compliance · Regulation (EU) 2023/988
Since 13 December 2024, a consumer product cannot lawfully be placed on the EU market unless someone established in the Union is answerable for it. Most suppliers cannot hold that role. Most providers who can have never opened one of your cartons. We are in the unusual position of being able to do both.
The General Product Safety Regulation applies to every non-food consumer product sold in the European Union, regardless of where the seller is based and regardless of whether the sale happens in a shop or online. Its requirement is blunt: if no economic operator established in the Union is responsible for the product, the product may not be placed on the market.
That operator has to be identifiable on the product or its packaging, must be able to produce the technical documentation on request, must cooperate with market surveillance authorities and must act if the product turns out to be dangerous.
Who qualifies
An EU-established manufacturer, an authorised representative appointed in writing, the importer, or a fulfilment service provider. All four must be established in the Union.
Who cannot
A factory in Guangdong, a trading company in Hong Kong, a sourcing agent in Shenzhen. However good they are, they are structurally excluded from this role.
The consequence
In most sourcing arrangements the buyer ends up holding this obligation by default — usually without being told, and often without realising until an authority asks a question.
There is a whole industry selling the role as a subscription. It is legitimate and it satisfies the letter of the regulation. It also leaves a gap that only becomes visible when something is wrong.
To be fair to the address services: if you already have solid documentation and a supplier you trust, they do the job at a low price. The case for us is different — we are answerable for goods we have physically checked, which is worth something only if you care about the product as well as the paperwork.
STEP 1
We establish what actually applies to your product: GPSR alone, or GPSR plus a CE marking directive, plus any category-specific rules.
STEP 2
We review what the manufacturer holds — test reports, risk assessment, declaration of conformity — and say plainly whether it is sufficient or thin.
STEP 3
Our details go on the product or packaging as the responsible operator, together with the traceability information the regulation requires.
STEP 4
We keep the documentation available, respond to market surveillance requests, and act with you if a safety issue is ever raised.
Regulation (EU) 2023/988, the General Product Safety Regulation, has applied across all member states since 13 December 2024. It requires that every non-food consumer product placed on the EU market has a responsible economic operator established in the Union. If no such operator exists, the product cannot lawfully be placed on the market at all — this is a precondition, not a formality.
An EU-established manufacturer, an authorised representative appointed in writing, the importer, or a fulfilment service provider. A company registered outside the Union cannot hold it, which is why sourcing agents based in China or Hong Kong are structurally unable to offer this no matter how helpful they are otherwise.
An address service sells you a compliant name to print on packaging for a few hundred euros a year. It is legal and it fills the box. What it cannot do is tell you whether the goods in the container match the technical file, because it has never seen them. We hold the role for goods we have inspected — which is the difference between compliance on paper and compliance in fact.
Sometimes, but not automatically. We review the technical documentation first, and we need to be satisfied that the file is real and that the product matches it. Holding this role means we answer market surveillance authorities on that product, so we decline where the documentation is thin or where the category sits outside what we understand.
No. Where a product falls under a CE marking directive or regulation, those obligations continue to apply in full. GPSR sits alongside them and adds requirements around traceability, internal risk analysis and the responsible person. A product can be correctly CE marked and still be non-compliant under GPSR if nobody in the EU is answerable for it.
It depends on the category, the number of SKUs and how much documentation work is needed up front. Where we already import your goods, the role usually comes with the arrangement rather than as a separate line. Where we are taking it on for products someone else supplies, we quote after reviewing the file.
Describe the product and the volume. We come back with a workable structure, a quote including landed cost, and an honest lead time — or with the reasons we would not take it on.