Responsible Person (EU)

The Responsible Person (EU) is a legal or natural person established within the European Union who is designated to act on behalf of a non-EU manufacturer for the purpose of regulatory compliance when placing products on the EU market. For radio equipment, this role follows from Article 4 of Regulation (EU) 2019/1020 because the Radio Equipment Directive (RED) is one of the legal acts listed in Article 4(5) of that Regulation.

When is a Responsible Person Required?

This role applies to radio equipment placed on the EU market by manufacturers established outside the EU who do not have a physical presence in the Union. A Responsible Person must be designated to ensure regulatory accountability for:

• Providing the EU Declaration of Conformity (DoC) and technical documentation to market surveillance authorities.

• Cooperating with those authorities on preventive or corrective actions.

• Ensuring traceability and compliance information is available and maintained.

Legal Basis

The obligation to identify an EU-based responsible economic operator arises from Article 4 of Regulation (EU) 2019/1020. It applies to radio equipment because Directive 2014/53/EU (RED) is listed in Article 4(5) of the Regulation; it does not arise from Article 4 of the RED itself.

Key Requirements

The name, address, and contact details of the Responsible Person must be:

• Affixed to the product packaging, label, or accompanying documents.

• Clearly visible and legible for authorities and end users.

Important Distinction

The Responsible Person does not automatically assume the legal obligations of an importer or authorized representative. However, the roles can be fulfilled by the same entity, if so designated.

Acceptable Entities

The Responsible Person can be:

• An importer established in the EU.

• An authorized representative with a written mandate.

• A fulfillment service provider (e.g. logistics platform), under certain conditions.