GPSR requires that for each product there is an identifiable responsible person within the EU, someone whom regulators and consumers can contact. If the manufacturer is established outside the EU and no authorized representative or importer has been designated, the regulation establishes an order in which other parties in the supply chain can assume that role. That order is called the cascade: first the manufacturer itself is considered, then an authorized representative, then the importer, and only if none of those parties are identifiable can responsibility shift further to whoever actually places the product on the EU market.
For an online retailer or importer, what matters in particular is that this cascade is not an optional choice you make yourself. Whoever sources a product from a country outside the EU and places it on the EU market may find that in practice they act as a safety net once no other party has taken on the role of EU responsible person. That surprises entrepreneurs more often than expected, not because they want that role, but because no one else in the supply chain has picked it up.
Why this order exists
The cascade is designed to prevent a product from circulating without a contact point in the EU. A regulator or a consumer must be able to reach someone who can produce documentation and, if there is cause, respond to a safety signal about the product. Without a fixed order, a manufacturer outside the EU could simply remain out of reach while the product sits on the shelves of online shops and retailers. That is why the regulation first looks at who stands closest to the manufacturer, and only then at the parties further down the supply chain.
What this means for your role in the supply chain
Whether you fall into this cascade depends on the role you actually perform: whether you are an importer, fulfilment service provider, or merely a reseller of products already placed on the EU market earlier. The key point is that the cascade only comes into play when there is a gap in the supply chain: there is no manufacturer, authorized representative, or importer identifiable who fulfils that role. Once those parties are in place and their details are correctly stated on the product or packaging, the cascade does not apply to you.
That distinction is precisely why it makes sense to first clarify which role fits your situation, before you draw conclusions about your own position. With see in a few questions which role fits your situation you get an initial indication, separate from the question of whether you will ever fall into the cascade.
How to check whether a responsible person has already been designated
In practice, the first step is to ask your supplier or manufacturer who acts as the responsible person, and whether that name with address details appears on the product, packaging, or accompanying documentation. If that information is missing, it is a signal to look further, not automatically a conclusion that you assume the role. The regulation distinguishes between different parties in the supply chain, and which role each party bears depends on concrete facts such as who imports the product, under what name it is sold, and who handles customs formalities.
Because these questions can differ per product stream, it is sensible to record this for each product or per supplier rather than once for your entire catalogue. A supplier who designates an authorized representative today may drop that tomorrow, and then the situation changes without your online shop having done anything about it. An overview of how the different roles in the supply chain relate to each other is set out in the knowledge base with explanations per role and per obligation.
What this comes down to in practice
For many SMEs, this cascade remains theoretical because there is simply always an importer or authorized representative designated who fulfills the role. For companies that purchase directly from manufacturers outside the EU, without an intermediary presenting itself as responsible, the situation is different. In that case, it is worthwhile to explicitly document who bears which role, and not to assume it based solely on an invoice or a packing slip. How we build and keep the information on gpsria.eu current is explained on the page on the origin of our information.
Check yourself how this applies to you
Because the cascade depends on who can demonstrate which documents and data, a general statement about your own situation cannot be made without knowing those data. In case of doubt, it is advisable to consult the legal text on EUR-Lex or involve a lawyer or the competent supervisory authority, especially in a product flow where you work directly with a manufacturer outside the EU.
Would you like to first get a picture of your position in the chain before speaking with a lawyer? Do the free role check, or browse the frequently asked questions about roles and obligations for more background.