Do US Candle Sellers Need an EU Responsible Person? GPSR Explained

Published 2026-10-26 · All articles

Short answer: if you make your candles outside the EU and sell them to consumers in the EU, the EU General Product Safety Regulation (GPSR) expects an economic operator established in the EU to be responsible for them. That applies to sellers in the US, UK, Canada and Australia alike. Below is what the rule says, who can fill the role, and what to check before you sign up with anyone. This is general information, not legal advice.

What the regulation says

Regulation (EU) 2023/988 has applied since 13 December 2024. Article 16(1) says a product covered by the regulation shall not be placed on the market unless there is an economic operator established in the Union responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020. Those tasks include keeping documentation available for authorities, cooperating with them, and informing them when a product presents a risk.

Two more articles matter for online sellers:

• Art. 16(3): that operator's name, postal address and electronic address must be shown on the product, its packaging, the parcel or an accompanying document.
• Art. 19(b): when the manufacturer is not in the EU, the same details must appear in the online listing.

Article 4 explains when an online offer counts as being made to EU consumers: if the seller directs activities to one or more Member States. Shipping to EU countries and accepting EU orders is the usual case.

Who can be your Responsible Person

GPSR points to Article 4 of Regulation (EU) 2019/1020, and Etsy's Seller Handbook lists the same four types:

1. An EU-established manufacturer. Not you, if you make candles in Ohio.
2. An importer established in the EU.
3. An authorised representative in the EU, appointed by you under a written mandate (GPSR Art. 10).
4. A fulfilment service provider established in the EU, where none of the above exists.

For most small non-EU candle shops, option 3 is the realistic route: a company in the EU that signs a written mandate and is named as your Responsible Person. Etsy's Help Center names some third-party providers it has partnered with, and Amazon offers provider directories in Seller Central. We do not recommend any provider and have no affiliate links.

What it means in practice for a candle shop

• Before listing: sign a mandate, get the provider's exact legal name, EU postal address and email.
• On Etsy: add them as an economic operator under Shop Manager → Settings → Partners you work with, or in each listing's Manufacturers and Product safety info box.
• On Amazon EU: submit the Responsible Person contact in Account Health → Regulatory Compliance, per storefront, then attach safety information to your ASINs.
• On the product: print their details on the label, the box, or an insert in the parcel. A listing alone does not cover Art. 16(3).
• Documentation: as manufacturer you still owe an internal risk analysis and technical documentation, kept for 10 years (Art. 9(2)–(3)). Your Responsible Person will likely ask for it.

Questions to ask a provider

• Which EU country are you established in, and what is your legal entity name?
• Is the mandate written, and what exactly do you do if an authority contacts you?
• Is pricing per product, per SKU, or per brand? What counts as one product for candles in different scents?
• Do you review labels, or only act as the contact point?
• How do you forward complaints and accident reports (GPSR Art. 9(11) and Art. 20)?
• What happens to listings and stock already sold if I cancel?

What about stopping EU sales?

Etsy lets sellers opt out of selling to EU/EEA and Northern Ireland buyers in their settings. That avoids the issue but gives up the market. It is a business choice; there is no wrong answer.

A note on the UK and Northern Ireland

Great Britain is outside the EU, so a UK maker selling into the EU needs an EU-established operator too. Northern Ireland is treated differently under the Windsor Framework, and Etsy refers to EU, EEA and Northern Ireland together. If you are in or ship to Northern Ireland, check current UK government guidance.

Getting the listing text right

Once you have your Responsible Person's details, you still need the manufacturer block, product identification and safety warnings. Our free browser tool CandleGPSR (gpsr.ludegong.com) will not let you generate output for a non-EU shop until you enter Responsible Person details, and it explains the rule on its RP guide. For offline files, the CandleGPSR Template Pack ($12) includes copy-paste safety blocks for six candle and home-fragrance types and Etsy/Amazon checklists: Gumroad · Payhip.

Disclaimer: General information, not legal advice. CandleGPSR does not act as, appoint or provide an EU Responsible Person, and using our tool or templates does not make a product compliant or guarantee marketplace approval. Non-English template texts are machine-drafted and need native-speaker review. Read the Regulation and current marketplace guidance, and consult a qualified adviser.

Sources: Regulation (EU) 2023/988, Art. 4, 9, 10, 16, 19, 20 (OJ L 135, 23.5.2023); Etsy Help Center, "What is the General Product Safety Regulation (GPSR)?" (https://help.etsy.com/hc/en-us/articles/28211364687383); Etsy Seller Handbook (https://www.etsy.com/seller-handbook/article/1093438529659); Amazon Seller GPSR guide (https://m.media-amazon.com/images/G/28/AS/AGS/SU/Seller_Facing_GPSR_Guide_202408.pdf).