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Free template

GPSR responsible person template

Copy the product page block, the parcel line and a mandate outline for an authorised representative. Written from Articles 10, 16 and 19 of Regulation (EU) 2023/988, with the fill-in fields in square brackets.

Who needs it

Every store that offers consumer products to shoppers in the EU, including stores based outside the EU. Since 13 December 2024 a product may not be placed on the EU market unless an economic operator established in the EU is responsible for it (Article 16(1)), and every online listing must show the manufacturer, the EU responsible person where the manufacturer is outside the EU, the product identification and the required warnings (Article 19). The GPSR overview explains the roles; the GPSR product page guide shows where each item goes in Shopify.

1. Product page block (Article 19)

For a product whose manufacturer is outside the EU. Paste it into the product description, a metafield your theme displays, or the app that shows it, and translate the warnings for each market.

Product page block, non-EU manufacturer

Manufacturer: [Legal name, registered trade name or trade mark]
Postal address: [Street and number, postcode, city, country]
Email: [safety@your-brand.com]

Responsible person in the EU (Article 16, Regulation (EU) 2023/988): [Company name]
Postal address: [Street and number, postcode, city, EU country]
Email: [contact@eu-representative.eu]

Product: [Product name], type or model [model name], identifier [model number, GTIN or article number]
Warnings and safety information: [Copy every warning from the label, the packaging or the leaflet, in the language the country you sell to requires]

For a product made by an EU manufacturer, leave the responsible person out: the manufacturer is the responsible person itself.

Product page block, EU manufacturer

Manufacturer: [Legal name, registered trade name or trade mark]
Postal address: [Street and number, postcode, city, EU country]
Email: [safety@your-brand.com]

Product: [Product name], type or model [model name], identifier [model number, GTIN or article number]
Warnings and safety information: [Copy every warning from the label, the packaging or the leaflet, in the language the country you sell to requires]

2. Parcel or packaging line (Article 16(3))

The responsible person's name and contact details must also be on the product, its packaging, the parcel or an accompanying document. One line on the delivery note or a sticker on the parcel covers it.

Parcel or delivery note line

EU responsible person (Regulation (EU) 2023/988, Article 16): [Company name], [street and number, postcode, city, EU country], [contact@eu-representative.eu]

3. Mandate outline for an authorised representative (Article 10)

A manufacturer may appoint an authorised representative by written mandate (Article 10(1)); a non-EU manufacturer with no EU importer usually does, so that the representative can be the responsible person of Article 16. The mandate names the tasks the representative performs; Article 10(2) sets the minimum. This outline lists what the document should contain. It is not a contract: have the final text drawn up or checked by a lawyer in the representative's country.

Mandate outline

WRITTEN MANDATE FOR AN AUTHORISED REPRESENTATIVE
Regulation (EU) 2023/988, Article 10

1. Parties
   Manufacturer: [Legal name, registered office address, country, registration number]
   Authorised representative: [Legal name, registered office address in the EU, registration number]

2. Products covered
   [Product names, types or models, and identifiers; or "all consumer products placed on the EU market by the manufacturer under the brand [brand]"]

3. Tasks of the authorised representative
   The authorised representative performs the tasks specified in this mandate and provides a copy of it to the market surveillance authorities on request. For the products in point 2 it shall at least:
   a) provide a market surveillance authority, on that authority's reasoned request, with all information and documentation necessary to demonstrate the safety of the product, in an official language the authority understands;
   b) inform the manufacturer where it considers or has reason to believe that a product is dangerous;
   c) inform the competent national authorities, through a notification in the Safety Business Gateway, of any action taken to eliminate the risks posed by the products covered by this mandate, where the manufacturer has not already provided that information or on the manufacturer's instruction;
   d) cooperate with the competent national authorities, at their request, on any action taken to eliminate the risks posed by the products covered by this mandate.
   Where the authorised representative is the responsible person of Article 16 for these products, this mandate also designates it to perform the tasks in Article 4(3) of Regulation (EU) 2019/1020 on the manufacturer's behalf (Article 4(2)(c) of that Regulation) and the regular checks in Article 16(2).

4. Documents and contact details
   The manufacturer keeps the technical documentation for each product for ten years from the placing on the market (Article 9(3)) and gives the authorised representative what it needs to answer the authorities. The authorised representative's name, postal address and electronic address appear on the product or its packaging, on the parcel or an accompanying document, and on every online listing where the manufacturer is not established in the EU.

5. Term
   This mandate starts on [date] and runs until [date or "terminated in writing by either party with [30] days' notice"]. Tasks for products already placed on the market continue for the period the Regulation requires.

6. Signatures
   For the manufacturer: [name, position, date, signature]
   For the authorised representative: [name, position, date, signature]

How to fill it in

  • Manufacturer. The legal entity that makes the product or has it made and sells it under its own name or mark, with a postal address and an email where it can be contacted (Article 9(6)). If you sell your own brand, this is you.
  • Responsible person. Fill it in when the manufacturer is outside the EU. Use the importer or the authorised representative named in your mandate; your EU fulfilment provider counts only when neither is established in the EU (Article 4(2) of Regulation (EU) 2019/1020). Never copy an address from another seller.
  • Product. Enough to identify this product: the name, the type or model and an identifier such as a model number or GTIN, next to the product photos (Article 19(c)).
  • Warnings. The warnings the law requires on the product, its packaging or an accompanying document, as text, translated for each EU country you sell to (Article 19(d)). A product with no required warning gets no warning line.
  • One block per manufacturer, not per product. Keep the manufacturer and responsible person details in one place and attach them to every product from that supplier; the product line alone changes.

Frequently asked questions

Who can be the responsible person in the EU?

An economic operator established in the EU: the manufacturer, the importer where the manufacturer is outside the EU, an authorised representative with a written mandate from the manufacturer, or an EU fulfilment service provider for the products it handles when none of the others is established in the EU (Article 16(1) of Regulation (EU) 2023/988 with Article 4(2) of Regulation (EU) 2019/1020).

Does an EU manufacturer need a separate responsible person?

No. An EU manufacturer is the responsible person itself. Article 19 asks for the responsible person on the listing when the manufacturer is not established in the EU, so where the manufacturer is established in the EU the product page shows the manufacturer block alone, wherever the product was made.

Where does the block go on a Shopify product page?

On the product page itself, visible before the purchase: in the description, in a metafield your theme shows, or through an app. Shopify has no built-in GPSR fields. Complimus shows the manufacturer and EU responsible person details on every product page, free on every plan.

Does the responsible person also go on the parcel?

Yes. Article 16(3) requires the name and contact details of the responsible person on the product, its packaging, the parcel or an accompanying document. The product page block covers the listing duty of Article 19; the parcel line covers Article 16(3).

Complimus helps you apply these rules. It is not legal advice, and you remain the trader responsible for what your storefront shows. The template is a starting point for your own text, not a legal document checked for your store.