By C. Chai, director, UIC International B.V. Published 2026-08-20, last updated 2026-08-21. How we write these.
The General Product Safety Regulation requires an economic operator established in the EU to stand behind a consumer product. For a branded vape device, that role sits with the business placing the finished product on the market.
The General Product Safety Regulation (EU) 2023/988 is the EU baseline for consumer product safety. It has applied since 13 December 2024 and replaced the earlier general product safety directive. It does not set technical specifications for a vape device. It sets the duty to place only safe products on the market, the traceability information a product must carry, the documentation an operator must hold, and the obligation to act when a product turns out to present a risk.
The regulation is a safety net. Where a specific EU rule already covers an aspect of the product, that rule governs that aspect, and the GPSR covers what is left. For a battery-powered device that means the GPSR sits alongside CE, RoHS and the battery rules rather than replacing them. See the compliance pillar for how the frameworks divide up.
A product may not be placed on the EU market unless there is an economic operator established in the Union that is responsible for it. The point is enforcement. A market surveillance authority in a member state needs a named business with an address inside the EU that it can write to, request documentation from, and hold to a corrective action. A factory outside the EU and an offshore brand entity give an authority nothing it can reach.
The list of who can fill the role is not in the GPSR itself. The GPSR points at Article 4 of Regulation (EU) 2019/1020, which names four: a manufacturer established in the EU, an importer where the manufacturer is not established in the EU, an authorised representative appointed in writing by the manufacturer, or a fulfilment service provider established in the EU. The fourth is residual rather than optional: a fulfilment service provider qualifies only where none of the first three exists in the Union, so it is not a route you can simply choose. Which of those applies depends on how your business is structured and where it sits. That is a legal question about your company, not a product question, so take advice on it rather than copying another brand.
The tasks are administrative and continuing. In broad terms the responsible person verifies that the required conformity documentation and technical documentation have been drawn up, keeps them available for the authorities for the period the law requires, provides information and documentation on request, and informs the authorities when it has reason to believe the product presents a risk. The contact details for the role appear on the product, on its packaging, on the parcel or in an accompanying document, which is a wider set than the product and its box alone. Major marketplaces now ask for these details at listing, so check the policy of each marketplace you sell on.
Two consequences follow. First, whoever holds the role has to actually possess the file, so the documentation has to be collected before launch and not after a query arrives. Second, the file has to match the product being sold, not a similar model. Confirm the retention period and the exact contact format required in your market with your own adviser, since practice differs.
A business that places a product on the market under its own name or trademark is generally treated as the manufacturer of that product for these purposes, and substantially modifying a product can have the same effect. Buying an empty disposable and printing your brand on it is the ordinary case. The upstream supplier does not carry your obligations because your name is on the box, not its name.
Empty Vapes supplies documented empty hardware. The party that brands and places the finished filled product on the market carries the national registrations and the responsible person role. We can hand over what we hold for the hardware, and that is where our part ends.
| Role | Typically filled by | Main duties |
|---|---|---|
| Manufacturer | The business selling under its own name or trademark | Safety of the product, technical documentation, traceability marking |
| Importer | The business bringing the product into the EU | Checks the manufacturer has done its part, adds its own contact details |
| Authorised representative | An EU-established operator appointed in writing | Holds documentation, answers authorities, acts on the mandate given |
| Distributor | Wholesalers and retailers down the chain | Verifies the marks and details are present, does not sell an unsafe product |
| Hardware supplier | Empty Vapes | Supplies empty hardware and the documentation held for it |
Name the operator that will hold the role and record the appointment in writing if it is not your own EU entity. Assemble the product file: conformity documentation, test evidence and a documented risk assessment for the product as you sell it. Put the traceability information and the responsible person contact on the artwork before the print run, alongside the recycling marks covered in the WEEE registration guide. Then check what the conformity documentation actually says, which is the subject of the CE marking guide.
Trade guidance for B2B buyers, not legal advice. We sell empty hardware only; you are responsible for the fill and for finished-product compliance in your market. The buyer that brands the device and places the finished product on the market carries the national registrations and should take its own legal advice.
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