can I act as an EU responsible person with my own business registration number

Operating as responsible person with your own chamber registration number: usually possible

Yes, operating as a responsible person with your own chamber registration number is possible for most entrepreneurs in the Netherlands — provided the business is actually established in the Union. Article 16 of Regulation (EU) 2023/988 does not impose a separate licence or recognition requirement, but requires a market participant established in the Union capable of carrying out the associated tasks: being able to demonstrate product information, cooperating with requests from supervisory authorities, and taking action in a recall or other corrective measure. Anyone registered with the chamber of commerce in the Netherlands and able to meet those tasks can in principle fulfil that role themselves.

What matters is which role precedes it. An EU manufacturer can act as responsible person themselves, and the same applies to a company that is considered a manufacturer under the rule on private label on a purchased product — even if that company has not designed or manufactured anything itself. Whoever sources products from outside the EU and places them on the market in the Union for the first time is generally an importer, and they too can assume the role of responsible person as long as the establishment requirement and tasks are met. A pure distributor, who resells products from a party already present in the EU without making changes to them, does not need to fulfil this role — the obligations of a distributor lie elsewhere in the supply chain. Which role applies precisely depends on how the product enters the EU and who places it on the market first; see also the explanation on the allocation of roles between manufacturer, importer and distributor.

Where this follows from: Article 16 and Article 11

Article 16 of Regulation (EU) 2023/988 sets out the cascade of who can act as responsible market participant: first the manufacturer itself if established in the Union, otherwise the importer, then an authorised representative, and only as a last resort a fulfilment service provider. Article 11 elaborates further on the obligations of the importer, including the tasks associated with this role once it is designated as responsible person. From this cascade it follows that a manufacturer or importer with a valid chamber registration number and an establishment in the Union generally stands first in that queue, and can therefore act without appointing an external party.