Which GPSR role are you actually operating under — and why does it change the workflow?
Official source: Article 4 of EU Regulation 2023/988 defines key supply-chain parties relevant to product safety, including:
- The manufacturer — the entity that designed, produced, or had the product produced under its name or trademark.
- The importer — the entity that places the product on the EU market from a third country.
- The distributor — anyone in the supply chain who makes the product available on the EU market without being the manufacturer or importer.
Official source: Article 16 of EU Regulation 2023/988 sets out the requirement for an EU-established economic operator for certain products placed on the market.
For Amazon EU sellers sourcing from China, the practical workflow often splits like this:
Brand owners (selling under their own trademark, having product produced under their name): you may be treated as the manufacturer for GPSR workflow purposes, or may need an EU Responsible Person / Article 16 economic operator arrangement tied to your products. In that case, the compliance data — technical files, conformity declarations, test reports — will usually sit with you, your appointed representative, or your upstream manufacturer, depending on how your supply chain is structured.
Third-party sellers (reselling another brand's product): you are often operating in a distributor role. In practice, that usually means you are not the party originating the manufacturer's compliance file. Your workflow is more likely to involve verifying that the relevant compliance documentation and EU economic operator details already exist, rather than creating a new filing from scratch.
The Octo GPSR Role-Check — 3 questions before opening a bulk upload
| Question | Brand owner answer | Third-party seller answer |
|---|---|---|
| Does the product carry your trademark or name? | Yes | No |
| Who holds the technical file and test reports? | You, your manufacturer, or your Responsible Person / compliance representative | The manufacturer or the brand owner |
| Who is the EU Responsible Person for this product? | Your designated RP / Article 16 operator | The manufacturer's or brand owner's designated RP / Article 16 operator |
If you answered "third-party seller" to all three: you are usually not the party originating GPSR compliance uploads for this product. Your role is more likely to be confirming that the relevant Responsible Person / economic operator record already exists in the system — not creating a new one.
Octo methodology: this is one of the first role checks we use when diagnosing large-batch GPSR failures. Where a reseller is trying to submit compliance data they do not control, rejection rates can be materially higher.
What does the brand owner workflow usually look like vs. the third-party seller workflow?
Official source (GPSR): The regulation defines the underlying economic-operator roles and documentation responsibilities.
Amazon process (platform workflow): Amazon's Manage Your Compliance flow and bulk-upload tooling may map those roles into account-level and product-level submission steps, based on practitioner-reported workflow behavior.
Octo inference: The operational split below is a working model for diagnosing Amazon EU GPSR upload issues, not a statement of legal responsibility in every supply-chain configuration.
Brand owner workflow:
- Appoint an EU Responsible Person / Article 16 economic operator where required — a legal entity established in the EU who can hold the relevant role for your products.
- Register that Responsible Person / operator in Amazon's Manage Your Compliance dashboard, where Amazon's workflow explicitly calls for it.
- Assemble the underlying compliance file per product type: risk assessment, test reports, materials declaration, declaration of conformity, traceability data, or equivalent supporting documents.
- Upload per-ASIN data fields through Amazon's compliance upload tool where required. Practitioner-reported Amazon workflow guidance indicates field sets and submission behavior may depend on marketplace and product mapping rules.
- If you see broad rejection across a batch, first check whether the account-level Responsible Person / operator setup is active before assuming the issue is in the per-ASIN file.
Third-party seller workflow:
- Check whether the product's brand owner already has an EU Responsible Person / Article 16 operator associated with the product listing or compliance record.
- If the brand owner has not filed: contact them or the upstream supplier. In many cases, you may not be the party expected to originate that filing.
- If the brand owner has filed and the product is still blocked: the issue may be a data mismatch, listing linkage issue, or marketplace-specific missing field.
- If Amazon's workflow explicitly requires a submission from your account, follow that requirement. In practitioner-reported cases, duplicate or conflicting submissions can prolong resolution.
What do 100% GPSR bulk-upload rejections usually indicate?
A 100% rejection pattern is usually a signal to check role alignment and account-level setup first, before debugging individual ASIN files. It does not prove a single root cause, but it often points to an upstream workflow issue rather than 5,000 separate product-level defects.
Red flags in a bulk GPSR upload that has produced 100% rejections
- 100% rejection across all marketplaces — first check whether the Responsible Person / account-level setup is active and whether the filing role is aligned. This pattern is more consistent with an upstream workflow issue than with thousands of unrelated per-ASIN defects.
- Partial acceptance on one marketplace, rejection on others — one plausible explanation is a per-marketplace feed issue, including missing language or marketplace-specific fields for the rejected marketplace. Marketplace safety-information requirements are commonly language-specific, but the exact field behavior depends on Amazon's process.
- Single ASIN blocking multiple SKUs — one possible explanation is that the master sheet is keyed to the wrong reference field. Practitioner-reported Amazon workflow guidance suggests some GPSR upload flows may key the master sheet to manufacturer reference rather than ASIN. If so, re-keying may resolve cascading blocks.
Related Octo article: For the mechanics of the Layer 1 → master-sheet → per-marketplace bulk upload sequence, see the Octo GPSR Bulk Feed Sequence →
Track regulatory compliance signals across EU marketplaces via Octo Periscope →
Periscope use case: if you're managing a large EU catalog, use it to spot where compliance friction is showing up first, so your team can separate likely Amazon process issues from likely supplier-document gaps before reworking the full batch.
Frequently Asked Questions
Can a third-party Amazon EU seller handle GPSR compliance for products they resell? Usually not as the originating compliance filer for the manufacturer's documentation set. A third-party seller is often operating in a distributor role and may need to verify that the product already has the relevant EU economic operator and supporting documentation in place. Check the exact obligations in EU Regulation 2023/988 and your supply-chain position with a qualified compliance specialist.
Why does my bulk GPSR upload work for one EU marketplace but not others? One common explanation is marketplace-specific field or language requirements inside Amazon's workflow. A feed that passes on Amazon.de may still fail on Amazon.fr if the French-language safety information fields expected by Amazon are empty or missing. Practitioner-reported Amazon process guidance suggests testing one marketplace at a time before submitting the full batch.
What is the EU Responsible Person requirement under GPSR? Under EU Regulation 2023/988, certain products placed on the EU market need an EU-established economic operator who can serve as the point of contact for market surveillance authorities and hold or provide access to the relevant documentation. For products manufactured outside the EU, this is often handled by the brand owner, importer, or an appointed representative depending on the supply-chain setup.
*This article is sourcing intelligence on GPSR compliance workflows. It is not legal or regulatory advice. EU General Product Safety Regulation 2023/988 came into force December 13, 2024. Verify current compliance obligations with an EU product compliance specialist. Published 2026-05-22 by the Octo team.*