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Labelled goods in a distribution centre — EU responsible person under GPSR

Compliance · Regulation (EU) 2023/988

Your EU responsible person — held by a company that saw the goods

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.

GPSR Article 16Held on SIA DEXTRO (LV)Technical file reviewed firstWe answer the authorities
01 / The rule

A precondition, not a formality

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

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.

Who cannot

Anyone outside the EU

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

The gap lands on you

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.

02 / The difference

An address, or an operator who has seen the goods

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.

Criterion
Address-only service
Silentium Trade
Established in the EU
 Yes
Yes — SIA DEXTRO, Latvia
Has seen the goods
 Never
Inspected on our warehouse in China
Knows the factory
 No
We selected and vetted it
Checks the file against reality
 Reviews paperwork only
Compares the file with the physical batch
If a batch differs from the file
 Finds out when you do
Catches it before shipment
Relationship to your supply
 None — separate vendor
Same party that supplies the goods

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.

03 / How it works

Taking the role, step by step

STEP 1

Category review

We establish what actually applies to your product: GPSR alone, or GPSR plus a CE marking directive, plus any category-specific rules.

STEP 2

Technical file

We review what the manufacturer holds — test reports, risk assessment, declaration of conformity — and say plainly whether it is sufficient or thin.

STEP 3

Labelling

Our details go on the product or packaging as the responsible operator, together with the traceability information the regulation requires.

STEP 4

Ongoing

We keep the documentation available, respond to market surveillance requests, and act with you if a safety issue is ever raised.

Where we say noWe decline this role when the technical file is missing or clearly improvised, and when the category sits outside what we understand well enough to defend. Holding it means answering for the product — an operator who accepts anything without looking is selling you a signature, not protection.
04 / Related

Related

05 / Questions

Common questions

What exactly does GPSR require?

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.

Who is allowed to hold the role?

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.

How is this different from an address service?

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.

Will you take the role for products you did not supply?

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.

Does GPSR replace CE marking?

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.

What does it cost?

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.

06 / Enquiry

Tell us about the product

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.

WhatsApp
+852 6214 4877 — fastest way to reach us
Phone
+86 136 0045 3256 — China office
Working hours
Mon–Fri, 09:00–18:00 China time (UTC+8) — mornings in Europe, afternoons in the Gulf
Working languages
English · Chinese
EU entity
SIA DEXTRO · VAT LV44103144015 · EORI LV44103144015 — verifiable in the Latvian register and VIES
China entity
Hainan Silent International Trade Co., Ltd · USCC 91460204MADNWQ6808

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