Martin Walian
Martin Walian, MBA & Certified Export Control Manager (CECM)
What Is an EU Authorised Representative?
The GPSR Guide for Amazon Sellers
If you sell products on Amazon Europe and you are not based in the EU, you need an EU Authorised Representative. This is not optional. Since December 2024, the General Product Safety Regulation (GPSR) makes it a legal requirement — and Amazon is already removing listings that do not comply.
1. What Is an EU Authorised Representative?
An EU Authorised Representative (EAR) is a legally registered entity inside the European Union that acts as your official point of contact for EU regulatory authorities, market surveillance bodies, and marketplaces like Amazon.
Put simply: if your business is not registered in the EU, you are legally required to appoint a company or individual that is — and that entity's name and address must appear on your product labelling, your Declaration of Conformity, and your Amazon listings.
Without a named, registered EU Authorised Representative, you cannot legally sell physical products in the EU. It is not a technicality. It is a hard legal requirement under GPSR.
2. What Is GPSR and Why Does It Matter?
The General Product Safety Regulation (EU) 2023/988 — commonly called GPSR — replaced the old General Product Safety Directive on 13 December 2024. It significantly tightened requirements for non-EU manufacturers selling into European markets.
The key changes:
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Named representative required. Every non-EU manufacturer must appoint a named EU Authorised Representative before placing products on the EU market. -
Physical labelling. The representative’s name, address, and contact details must appear on the product, packaging, or accompanying documentation.
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Marketplace enforcement. Amazon, eBay, and other EU marketplaces now require GPSR compliance as a condition of selling. Non-compliant listings are being removed.
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10-year document holding. The representative must hold your technical documentation for 10 years and respond to regulatory authorities on your behalf.
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Penalties. Non-compliance can result in product recalls, market bans, and fines enforced at member state level.
3. What Does an EU Authorised Representative Actually Do?
An EU Authorised Representative carries specific legal responsibilities under GPSR. They provide a registered EU address that goes on your product labelling and marketplace listings. They hold your technical documentation (Declaration of Conformity, test reports, technical files) for the legally required 10-year period. They respond to enquiries from EU market surveillance authorities on your behalf. And they cooperate with regulatory authorities if a product safety issue arises.
The representative does not take ownership of your products or become liable for product defects. They are your official compliance contact point within the EU.
4. Who Needs an EU
Authorised Representative?
You need an EU Authorised Representative if your business is based outside the European Union and you sell or intend to sell physical products in EU member states.
This includes:
selling directly on Amazon EU marketplaces. You likely already have CE marking and a technical file from your manufacturing process. GPSR now additionally requires a named representative on your listing.
Since Brexit, the UK is a non-EU country. If you previously sold into the EU without a separate representative, that arrangement is no longer compliant. You need a dedicated EU Authorised Representative.
If you’re expanding from domestic sales to European Amazon marketplaces, retailers, or your own EU-facing Shopify store, you need a named representative before your first EU sale.
If your product falls under the Radio Equipment Directive, you likely already have an EAR through your CE marking process. However, the new RED cybersecurity requirements (EN 18031) may require updated documentation and Notified Body involvement.
Amazon, eBay, Etsy, Shopify with EU fulfilment, Walmart Marketplace, or direct-to-retailer.
Note for UK businesses: a UK Responsible Person is a separate legal requirement for selling in Britain. It does not substitute for an EU Authorised Representative, and vice versa. If you sell in both markets, you need both.
5. What Happens If You Don’t Have One?
The consequences are direct:
Amazon has been enforcing GPSR compliance across all EU marketplaces since December 2024. Sellers without a named representative in their listing are being delisted. eBay, Etsy, and other platforms are following.
Distributors, retailers, and fulfilment partners in the EU may refuse to work with you without a compliant representative in place.
EU market surveillance authorities can order product recalls, impose market bans, or issue fines.
6. What to Look for When Choosing a Service
Not all EU Authorised Representative services deliver the same level of support. Here is what actually matters when choosing a provider:
The key changes:
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Active compliance support, not just an address The cheapest services provide a name and address on paper but do not actively respond to regulators, hold documentation properly, or monitor regulatory changes. If a market surveillance authority contacts your representative and gets no response, the consequences fall on you. Choose a provider that actively manages your account.
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10-year document holding with a documented process GPSR requires your technical documentation to be held for 10 years. Your representative must have a proper system for storing and retrieving your technical file, test reports, and Declaration of Conformity. If a regulator requests these documents five years from now, your representative must produce them.
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Regulatory monitoring GPSR is not the only regulation affecting your products. Depending on what you sell, you may also be subject to the Radio Equipment Directive (RED), Toy Safety Directive (EN 71), Low Voltage Directive, or upcoming Cyber Resilience Act. A capable representative monitors changes to relevant regulations and alerts you before they affect your products.
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Fast onboarding If your listing has been removed or you have an urgent market access deadline, you need credentials fast. A legitimate service should have you active within 24-48 hours of sign-up.
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Dual-market coverage If you sell in both the EU and UK, look for a provider that covers both jurisdictions under one account. Managing separate providers for EU and UK representation adds unnecessary complexity and cost.
7. EU Authorised Representative vs UK Responsible Person
These are two separate legal requirements for two separate markets. The EU Authorised Representative covers all 27 EU member states under GPSR. The UK Responsible Person covers Great Britain under UK product safety legislation (UK PSTR). Northern Ireland follows EU rules under the Windsor Framework.
If you sell on both Amazon EU and Amazon UK — which most international sellers do — you need both. Some providers offer combined EU + UK representation under a single subscription.
8. How to Appoint an EU Authorised Representative
The process is straightforward:
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1. Contact a provider and confirm your products and markets are covered.
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2. Choose your plan — EU-only or EU + UK combined.
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3. Complete a short onboarding form with your product details and existing documentation (Declaration of Conformity, technical file).
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4. Receive your credentials — the representative’s name, registered address, and contact details — within 24-48 hours.
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5. Update your product labelling, documentation, and marketplace listings with the representative’s details.
9. Frequently Asked Questions
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Do I need a separate representative for each product? No. One EU Authorised Representative can cover all your product lines and categories.
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My Amazon listing was removed — how fast can this be resolved? With a legitimate provider, you can have your credentials within 24-48 hours. Once you update your Amazon listing, reinstatement typically takes a few business days.
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My Amazon listing was removed — how fast can this be resolved? With a legitimate provider, you can have your credentials within 24-48 hours. Once you update your Amazon listing, reinstatement typically takes a few business days.
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I’m a UK manufacturer — do I now need an EU representative? Yes. Since Brexit, the UK is treated as a non-EU country under GPSR. If you sell into the EU, you need an EU Authorised Representative. This is separate from any UK Responsible Person arrangement you may have for the British market.
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I already have CE marking — do I still need an EAR? CE marking and EU Authorised Representation are related but separate requirements. CE marking demonstrates your product meets applicable EU safety standards. An EAR is the entity responsible for being your regulatory contact within the EU. You need both. If you obtained CE marking through a testing lab or Notified Body, they may have arranged an EAR as part of the process — check your existing documentation.
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My products are IoT / wireless — does RED cybersecurity affect me? If your product falls under the Radio Equipment Directive and has wireless connectivity, the new cybersecurity requirements (EN 18031) that became mandatory in August 2025 likely apply. This is a separate compliance requirement from GPSR but your EU Authorised Representative should be able to advise on or coordinate both.
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Can my EU distributor act as my representative? Only if they have explicitly agreed to take on the legal role of importer and accept GPSR responsibility. Most distributors will not accept this liability. If your distributor has not formally agreed, you still need a dedicated EU Authorised Representative.
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I sell on eBay / Etsy / Shopify — does this apply to me too? Yes. GPSR applies to all products sold in the EU regardless of the sales channel. Amazon is currently the most aggressive enforcer, but eBay, Etsy, and other platforms are implementing similar requirements.
