A private-label EV charger cannot simply be shipped from a factory in China to a customer in Germany or France. EU law requires a business established in the EU to stand behind the product, with its name and contact details on the product, packaging or accompanying documents. Sellers often call this the EU responsible person.
Two pieces of law drive the requirement: Article 4 of the Market Surveillance Regulation (EU) 2019/1020 and the General Product Safety Regulation (EU) 2023/988, known as GPSR. This article explains both and how they affect brands, importers and online sellers. It is part of our OEM and private-label EV charger guide.
What changed on 13 December 2024
The European Commission’s GPSR factsheet confirms that the regulation has applied to businesses and national market surveillance authorities since 13 December 2024, and that products must carry information on an economic operator located in the EU that is responsible for them. The official text of Regulation (EU) 2023/988 is published on EUR-Lex. It replaced the earlier General Product Safety Directive.
For EV chargers the EU-based operator requirement was not entirely new. Chargers fall under CE marking legislation such as the Low Voltage, EMC, Radio Equipment and RoHS directives, and Article 4 of Regulation 2019/1020 already required an EU economic operator for those products from 16 July 2021. GPSR extends the principle to consumer products generally and adds rules on online sales, traceability and accident reporting.
Who can be the EU economic operator
Under Article 4 of Regulation (EU) 2019/1020, one of the following must be established in the EU:
| Operator | Who it usually is | Notes for private label |
|---|---|---|
| Manufacturer established in the EU | A brand based in an EU member state | An EU company selling under its own brand is the manufacturer |
| Importer | The EU business that first places the product on the EU market | Common when an EU distributor buys from a non-EU brand |
| Authorised representative | A company appointed by written mandate from the manufacturer | Used by non-EU brands selling directly or through marketplaces |
| Fulfilment service provider | A warehousing or fulfilment business | Only where no manufacturer, importer or authorised representative is in the EU |
A Chinese factory cannot fill this role from China, and neither can a brand based only in the US, Canada or the UK. The Commission’s guidelines on Article 4 explain how the roles work in practice.
What the responsible person must do
The tasks come from Article 4(3) of Regulation 2019/1020. In summary, the EU operator must:
- Verify that the EU declaration of conformity and technical documentation have been drawn up, and keep the declaration available to authorities.
- Give authorities the information and documentation needed to show conformity, on request, in a language they understand.
- Inform authorities when it has reason to believe a product presents a risk.
- Cooperate with authorities on corrective action, such as a withdrawal or recall.
This is real responsibility. A responsible person who cannot obtain the technical file from a non-EU brand or factory is exposed, so serious service providers ask to see the file before accepting a mandate. Our guide to CE marking for private-label chargers explains what the file should contain.
Labels, traceability and online listings
Under GPSR, manufacturers must make sure products carry a type, batch or serial number, together with the manufacturer’s name, postal address and electronic address. The EU operator’s details must appear on the product or, where that is not possible, on the packaging, the parcel or an accompanying document.
For distance sales, GPSR also requires the online listing to show the manufacturer’s name and contact details, the EU responsible person where the manufacturer is outside the EU, information identifying the product, and any warnings or safety information. Marketplaces have added fields for this. If you sell through your own shop or a marketplace, see our checklist for selling portable EV chargers online.
Common private-label scenarios
EU brand buying directly from the factory
You are the manufacturer and also the operator established in the EU. Your name and address go on the label, and you hold the technical file.
Non-EU brand selling into the EU
You remain the manufacturer for CE purposes, but you need an EU importer or authorised representative. Agree in writing who keeps the file, who answers authorities, and who handles accident reports and recalls.
EU distributor importing a third-party brand
The distributor is the importer and must check the CE marking, documentation and labels before placing products on the market. A distributor that puts its own brand on the charger becomes the manufacturer, which also has product liability consequences; see product liability for private-label charger brands.
A practical checklist
- Decide who the EU operator is before artwork is final, because the name and address go on labels and packaging.
- Sign a written mandate if you use an authorised representative.
- Give the EU operator access to the technical file and declaration of conformity.
- Add batch or serial numbers so a recall can be targeted.
- Update marketplace listings with the required manufacturer and operator details.
- Set up a process for complaints, accidents and corrective action.
EVDANCE prints your brand and packaging details as part of private-label orders, and our reseller and distributor program supports EU partners with product documentation. This article is general information, not legal advice; confirm your setup with a lawyer or compliance specialist. Questions about a specific project can go to our team.
Key Takeaways
- The GPSR has applied since 13 December 2024 and requires an EU-established economic operator to be responsible for products sold in the EU.
- For CE-marked chargers, Article 4 of Regulation 2019/1020 has required an EU economic operator since 16 July 2021.
- The operator can be an EU manufacturer, importer, authorised representative or, as a last option, a fulfilment service provider.
- The operator’s name and contact details must appear on the product, packaging, parcel or accompanying document, and online listings must show the required details.
Sources & Standards
- European Commission — General Product Safety Regulation factsheet
- EUR-Lex — Regulation (EU) 2023/988 (GPSR)
- EUR-Lex — Regulation (EU) 2019/1020 on market surveillance and compliance of products
- European Commission — Guidelines on the practical implementation of Article 4 of Regulation (EU) 2019/1020
