Which EU economic operator does your product need?
GPSR Article 16 forbids placing consumer goods on the EU market without an economic operator established in the Union. Answer eight structured questions and the ladder routes deterministically — manufacturer, importer, authorised representative, or fulfilment service provider — citing Reg (EU) 2019/1020 Art 4 at every rung.
Routing rules + AR/FSP price ranges verified 2026-06-09. Refreshed quarterly; older than 120 days the verdict is held back.
GPSR economic operator ladder
The first rung that matches your supply-chain shape is the verdict. Order is Art 4(1) hierarchical — not free choice.
1 · EU-established manufacturer
If you are established in any EU-27 or EEA country, you are the economic operator. No designation needed; you carry GPSR Ch 3 duties yourself.
2 · EU importer
If a single or multiple EU importers place your goods on the market, each is an EO for the products it imports. Per-importer mandate; one AR contract cannot consolidate this.
3 · Authorised representative (AR)
Non-EU manufacturer with no EU importer and any DTC, marketplace, or B2B channel: a written AR mandate is required before any product is placed on the EU market.
4 · Fulfilment service provider (FSP)
Sole channel is Amazon FBA / 3PL and you do not appoint an AR: the FSP becomes EO of last resort under Art 4(1)(d). Contested by several MSAs — appointing an AR in parallel is the safe path.
Recommended EO role
Appoint an authorised representative (AR mandate)
- EO ladder rungs
- 4 Manufacturer · Importer · AR · FSP
- GPSR applies since
- 2024 13 Dec 2024 (Reg (EU) 2023/988)
- Designation duty
- 16 Art 16 · Reg 2019/1020 Art 4
Most non-EU manufacturers selling consumer goods directly into the EU need an authorised representative (AR).
Since GPSR (Regulation (EU) 2023/988) became applicable on 13 December 2024, no consumer product may be placed on the EU market unless an economic operator established in the Union is responsible for it (Art 16). The Reg (EU) 2019/1020 Art 4 ladder decides who that operator is — in order: an EU-established manufacturer, an EU importer, an authorised representative, or (last resort, contested) a fulfilment service provider. AR services typically run €150–€5,000/year. Routing rules and price ranges verified 2026-06-09.
Disclaimer: This tool is a routing estimator, not legal advice. Verdicts are derived deterministically from GPSR Art 16 + Reg (EU) 2019/1020 Art 4 + the harmonisation map in Annex I. The dataset is refreshed quarterly; older than 120 days it stops producing verdicts. Consult an EU compliance counsel or a notified body before relying on the verdict for a customs declaration, marketplace KYC, or mandate signing.
Frequently asked questions
When did GPSR start to apply?
Regulation (EU) 2023/988 (the General Product Safety Regulation) became applicable across the EU on 13 December 2024, replacing the 2001 General Product Safety Directive.
What is an economic operator under GPSR Article 16?
Article 16 forbids placing a consumer product on the EU market unless an economic operator established in the Union is responsible for the Art 4(3) tasks of Reg (EU) 2019/1020. The eligible roles are EU-established manufacturer, importer, authorised representative, and (last resort) fulfilment service provider.
Do I need an authorised representative if I sell direct-to-consumer from outside the EU?
Usually yes. If you are a non-EU manufacturer with no EU-established importer and you sell via your own website, a marketplace, or B2B, a written AR mandate must be in place before any product is placed on the EU market.
Is the Amazon FBA / fulfilment service my economic operator?
Only as a last resort under Art 4(1)(d) — when there is no manufacturer, AR, or importer established in the EU. Several market surveillance authorities contest treating the FSP as the EO, so appointing an AR in parallel is the safer path.
How much does an EU authorised representative cost per year?
Dedicated AR services start around €150/year for low-risk products and rise to roughly €5,000/year for legal-retainer, full-service arrangements covering complex or regulated categories. Mid-market SaaS-enabled services cluster around €500–€1,500/year.
Does an EU economic operator cover sales to Great Britain?
No. An EU EO designation does not cover the British market. GB sales fall under the UK General Product Safety Regulations 2005 (SI 2005/1803) and OPSS guidance — you appoint a separate UK Responsible Person. Northern Ireland stays inside the EU regime under the Windsor Framework.
Is this verdict legal advice?
No. It is a deterministic routing estimator derived from GPSR Art 16, Reg (EU) 2019/1020 Art 4, and the Annex I harmonisation map. Consult EU compliance counsel or a notified body before relying on it for a customs declaration, marketplace KYC, or signing a mandate.