GPSR and the EU Responsible Person: A Guide for Foreign Amazon Sellers

Vaytax Editorial Team

Licensed tax advisor · files with the Finanzamt

Vaytax is operated by FRADECO GmbH tax advisory firm, a Franco-German tax advisory firm specialising in cross-border German VAT compliance for international businesses. This guide is educational: GPSR is product-safety law, not tax, and we do not provide Responsible Person services. We explain it because it lands on the same foreign sellers we help with German VAT.

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If you sell to EU consumers from outside the EU, the GPSR is one of the obligations most likely to stop your sales overnight, and it has nothing to do with tax. Since 13 December 2024, marketplaces have been removing listings that lack an EU Responsible Person, and many foreign sellers first hear about it when an Amazon listing gets blocked. This guide explains what GPSR is, who needs a Responsible Person, what that person does, and how the requirement sits next to the German VAT obligation that the same EU activity triggers.

What is GPSR?

The General Product Safety Regulation (GPSR), formally Regulation (EU) 2023/988, is the EU's baseline product-safety law for consumer goods. It has applied directly in every EU member state since 13 December 2024, replacing the older General Product Safety Directive (2001/95/EC). It covers most non-food consumer products that are not already governed by sector-specific safety rules, and it applies regardless of whether the product is sold in a shop or online.

The change that matters most for foreign sellers is the rule that a product may only be placed on the EU market if there is an economic operator established in the EU responsible for it. If the manufacturer is outside the EU and there is no EU-based importer, the seller must designate an EU Responsible Person. Without one, the product is not allowed on the EU market.

What is an EU Responsible Person?

An EU Responsible Person is a person or company established in the EU that takes on defined product-safety responsibilities under Article 16 of the GPSR. They are the contact point that EU market surveillance authorities can reach inside the Union, and the party that must hold certain documentation and act if a product turns out to be unsafe.

A Responsible Person can be the EU-based manufacturer, an importer established in the EU, an authorised representative the seller appoints in writing, or, in some cases, a fulfilment service provider established in the EU. For a typical non-EU Amazon seller with no EU entity, this usually means appointing an authorised representative or using a service that provides one.

What the Responsible Person must do

Under Article 16 GPSR, the Responsible Person's core duties include:

• Verifying that a declaration of conformity or required safety documentation exists, and keeping that technical documentation available for the authorities for the required period.
• Providing the authorities, on request, with the information and documents needed to show the product is safe.
• Informing the authorities if they have reason to believe a product is dangerous, and cooperating on corrective action such as withdrawals or recalls.
• Being identifiable: their name (or trade name) and a contact address must appear on the product, its packaging, the parcel, or an accompanying document.

Because their details must be visible, a missing or invalid Responsible Person is easy for both marketplaces and regulators to spot.

Does Amazon require a Responsible Person?

Yes. Amazon requires sellers to provide a valid EU Responsible Person for products sold to EU customers, and it restricts or removes listings that do not have one. Amazon rolled this enforcement out around the 13 December 2024 application date, and it now surfaces Responsible Person details on product pages. Sellers add and manage these details in Seller Central, in the product-compliance and manufacturer / responsible-person sections.

The practical effect for a foreign FBA seller is direct: no Responsible Person on file means the listing can be suppressed, which stops sales of that product in the EU until the gap is fixed.

GPSR is not VAT: the foreign seller's compliance stack

This is the point that trips up the most sellers. GPSR is product-safety law. It does not register you for VAT, get you an EORI number, or cover packaging. A foreign company selling into Germany through Amazon FBA typically faces a stack of separate obligations, each governed by different rules and authorities:

• German VAT registration (tax): triggered the moment you store goods in Germany, with no minimum turnover for foreign companies. This is what Vaytax handles.
• EORI number (customs): needed to import goods into the EU at all. See our EORI guide for foreign sellers.
• LUCID / VerpackG (packaging): registration in the German packaging register for anyone shipping packaged goods to German consumers. See our LUCID guide.
• GPSR Responsible Person (product safety): the subject of this guide.

Each one is independent. Appointing a Responsible Person does nothing for your VAT position, and registering for VAT does nothing for GPSR. The sellers who stay out of trouble treat these as a checklist, not a single task.

How GPSR connects to your German VAT obligation

The trigger for GPSR and the trigger for German VAT often arrive together. The moment your products are stored in a German fulfilment centre and sold to EU consumers, you have both a product on the EU market (GPSR) and a taxable presence in Germany (VAT). Many sellers discover the whole stack at once, usually when Amazon flags a compliance gap.

Vaytax does not act as your Responsible Person, but the same German FBA stock that creates the GPSR question also creates a German VAT registration obligation, with no turnover threshold for foreign companies. That part we do handle, end to end, with a licensed German tax advisor: registration, the monthly USt-Voranmeldung, and the annual return. If you are setting up product compliance, it is the right moment to get the VAT registration moving too, because the Finanzamt timeline runs in weeks, not days.

What to do next

1. Identify who your Responsible Person will be (an EU-based importer, an authorised representative you appoint, or a compliance provider that offers the role). This is a product-safety decision, not a tax one.
2. Add the Responsible Person details in Seller Central and make sure they appear on your listings and packaging, so Amazon and authorities can see them.
3. Check the rest of the stack: EORI for customs, LUCID for packaging, and German VAT registration for tax. Missing any one of them can stop your sales.
4. Start the German VAT registration in parallel, because it takes the longest. That is the piece Vaytax can take off your plate.

Frequently Asked Questions

What is GPSR?

GPSR is the EU General Product Safety Regulation, Regulation (EU) 2023/988, which has applied across the EU since 13 December 2024, replacing the older General Product Safety Directive. It sets safety requirements for most consumer products and requires an economic operator established in the EU to be responsible for each product. For sellers based outside the EU, that means designating an EU Responsible Person before the product can be lawfully placed on the EU market.

Who needs an EU Responsible Person?

Any business selling covered consumer products to EU consumers where there is no EU-established manufacturer or importer must appoint an EU Responsible Person. This applies squarely to non-EU sellers (UK, US, China, and others) shipping to EU customers, including via Amazon FBA. The Responsible Person must be established in the EU, and their name and contact details must appear on the product, its packaging, or an accompanying document, and on the online listing.

Does Amazon require a Responsible Person under GPSR?

Yes. Amazon requires sellers to provide a valid EU Responsible Person for products sold to EU customers and restricts or removes listings that do not have one. Amazon began enforcing this around the 13 December 2024 GPSR application date. Sellers manage these details in Seller Central, in the product-compliance and manufacturer / responsible-person sections.

Is GPSR the same as VAT registration?

No. GPSR is product-safety law and the Responsible Person is a product-safety role. German VAT registration is tax law, triggered separately when you store goods in Germany or your distance sales pass the EU thresholds. They are independent obligations that often hit the same Amazon FBA seller at the same time, along with an EORI number for customs and LUCID packaging registration. Meeting one does not satisfy the others.

Does Vaytax act as my GPSR Responsible Person?

No. Vaytax is a German tax advisory service; the EU Responsible Person role is a product-safety function, not a tax one, so we do not act as your Responsible Person or authorised representative. Specialist product-compliance providers and some EU-based fulfilment partners offer that service. What Vaytax does handle is the German VAT registration and filing obligation that the same German FBA stock triggers.

What happens if I do not comply with GPSR?

Without a valid EU Responsible Person, marketplaces such as Amazon can restrict or remove the affected listings, which stops your sales. EU national market surveillance authorities can also order corrective measures, withdrawals or recalls of unsafe products, and impose penalties, which vary by member state. Because the Responsible Person details must be visible on listings, non-compliance is easy for both marketplaces and authorities to detect.