German compliance answers / GPSR EU rep
Do Chinese sellers need a GPSR EU representative?
Short answer
Yes. A product may only be placed on the EU market if an economic operator established in the Union is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020. GPSR Art. 16(1)
Where the manufacturer is not established in the Union, the online offer must show the responsible person's name, postal and electronic address. GPSR Art. 19(b)
Who can be the EU responsible operator?
An EU manufacturer, an importer, an authorised representative with a written mandate, or a fulfilment service provider established in the EU. Reg. (EU) 2019/1020 Art. 4(2)
Where else must it appear?
On the product, its packaging, the parcel or an accompanying document: name and contact details, including postal and electronic address. GPSR Art. 16(3)
Since when does it apply?
It applies from 2024-12-13. GPSR Art. 44, Art. 52
How high is the fine?
Penalties are set by the Member States and must be effective, proportionate and dissuasive. GPSR Art. 44, Art. 52
Deadlines and numbers
| GPSR applies from | 2024-12-13 GPSR Art. 44, Art. 52 |
|---|---|
| New product liability rules | apply to products placed after 2026-12-09 Directive (EU) 2024/2853 Art. 2(1), 8(1)(c), 22(1) |
| If the manufacturer is non-EU | liability extends to importer, authorised representative, fulfilment service provider Directive (EU) 2024/2853 Art. 2(1), 8(1)(c), 22(1) |
What does the statute say?
A product covered by this 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
Where economic operators make products available on the market online or through other means of distance sales, the offer of those products shall clearly and visibly indicate at least the following information: ... where the manufacturer is not established in the Union, the name, postal and electronic address of the responsible person within the meaning of Article 16(1) of this Regulation or Article 4(1) of Regulation (EU) 2019/1020;
Not checked here: the German fine amounts and EU representative service prices.
What to do: three steps
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Where does each statement come from?
- GPSR Art. 16(1) · read 2026-10-18
- GPSR Art. 19(b) · read 2026-10-19
- Reg. (EU) 2019/1020 Art. 4(2) · read 2026-10-18
- GPSR Art. 16(3) · read 2026-10-19
- GPSR Art. 44, Art. 52 · read 2026-10-18
- Directive (EU) 2024/2853 Art. 2(1), 8(1)(c), 22(1) · read 2026-10-18
What changed on this page? Changelog
- 2026-10-22 · First published; read dates are shown per source.
This page excerpts public legal texts and is not legal advice. The legal text prevails.