Resources / Answers / Beyond EPR: product safety and labels

Is the GPSR responsible person the same as the EPR authorised representative?

No. They come from different laws: one EU-wide responsible person for product safety, one EPR representative per country for packaging.

By Razvan Toma · Founder · Last checked 22 October 2026 · Sources below

No: different laws, different scope. The GPSR responsible person must be an economic operator established in the EU (Art. 16(1)), so one covers the whole EU market for the products it accepts; it keeps the technical documentation available, cooperates with market surveillance authorities and regularly checks products and labels. The EPR authorised representative is defined per member state: established in the country where you make packaging available, it fulfils your packaging obligations in that country.

So a non-EU brand selling to consumers in Germany, France and Spain may need one GPSR responsible person, established anywhere in the EU, and an EPR representative in each of the three countries. One provider can hold several of these roles, each under its own mandate. If your EU importer already acts as responsible person, you may not need a separate one for GPSR.

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