EU Responsible Person for Service Brands and White-Label Sellers: Compliance When You Don't Manufacture

Not every business selling products into the EU manufactures those products. Service brands, white-label sellers, private-label operators, and businesses that rebrand third-party goods for EU sale face a particular compliance challenge: they must appoint an EU Responsible Person for products they did not design, formulate, or manufacture. The regulatory obligation falls on the entity placing the product on the EU market under their name — and that entity is you, regardless of where the product was actually made.

This guide addresses the specific EU Responsible Person requirements for service brands and white-label operations, and explains how Eldris provides compliant EURP appointment regardless of your position in the supply chain.

Why the EU Holds You Responsible, Not Your Manufacturer

EU product safety regulations are structured around a principle of market responsibility. The entity that places a product on the EU market — meaning the entity whose name or brand appears on the product when it is made available to EU consumers — bears regulatory responsibility for that product's compliance. This is true whether you manufactured the product yourself, contracted a third-party manufacturer, or purchased finished goods and applied your own branding.

For cosmetics under Regulation 1223/2009, the Responsible Person is typically the manufacturer if they are within the EU, or the importer if the manufacturer is outside the EU. But for white-label and private-label sellers who place products on the market under their own name, the regulatory responsibility transfers to them. Your manufacturer may have produced the formulation, but your brand on the packaging makes you the entity that EU authorities hold accountable.

For general consumer products under EU 2019/1020, the economic operator obligations apply to importers, authorised representatives, and fulfilment service providers — but the brand owner placing the product on the EU market carries the primary responsibility for ensuring an EU-based contact is identified.

The White-Label Compliance Gap

White-label sellers often assume that compliance is handled upstream in the supply chain. The manufacturer provided a Certificate of Analysis. The supplier confirmed EU compliance. The product has CE marking. Surely someone, somewhere, has already appointed an EU Responsible Person.

In most cases, they have not. Your manufacturer's EU Responsible Person — if they have one — covers the product under the manufacturer's brand. The moment you rebrand that product, apply your own packaging, and list it under your business name, a new EU Responsible Person appointment is required for your brand. The manufacturer's compliance does not transfer to your brand identity.

This is the gap that catches white-label sellers. The product itself may be fully compliant in terms of formulation, testing, and safety documentation. But the brand selling it into the EU lacks its own EU Responsible Person, and that single missing element renders every listing, shipment, and sale technically non-compliant.

Service Brands and the Documentation Question

Service brands — businesses that provide a service layer around physical products, such as subscription boxes, curated collections, or bundled product offerings — face an additional documentation challenge. When your business selects, bundles, and sells products from multiple manufacturers under your service brand, each product in your catalogue may originate from a different supply chain with different compliance documentation.

Your EU Responsible Person must be able to present the relevant safety data for each product upon request from authorities. For cosmetics, this means having access to each product's PIF and CPNP notification. For general consumer products, it means access to each product's Declaration of Conformity and technical file.

Eldris handles this by acting as the named EU contact who can be reached by authorities. Eldris does not create, store, or manage your PIFs, CPNP notifications, or Declarations of Conformity — that remains your responsibility. But Eldris stands as the EU-facing point of contact, handles initial authority enquiries, and loops you in to provide the specific documentation requested. This separation of roles is critical: your supply chain handles the documentation, and Eldris handles the regulatory contact obligation.

How Eldris Works for Service Brands and White-Label Operations

The Eldris onboarding process for service brands and white-label sellers is identical to the process for direct manufacturers. You submit your product information — names, SKUs, and descriptions — through the Eldris portal. Eldris generates your EU Responsible Person appointment certificate within approximately 60 minutes. You manage all compliance documentation, SKU updates, and certificate regeneration from the centralised dashboard.

EldrisAi OÜ (Reg. No: 3162734, Tallinn, Estonia) is appointed as your EU Responsible Person. The EU address provided on your certificate is the address you display on your rebranded packaging and marketplace listings. This is the address that EU authorities contact when they have questions about your product, and Eldris handles the initial response.

For white-label sellers managing multiple product lines from different manufacturers, the Eldris dashboard provides a single compliance management point. All products — regardless of manufacturer origin — are managed under one appointment, one dashboard, and one set of compliance documentation.

Multi-Brand, Multi-Manufacturer Compliance

Many service brands and white-label operations run multiple brand identities simultaneously. A single business might operate three or four brands, each sourcing products from different manufacturers, each targeting different market segments. Under EU regulations, each brand that places products on the EU market requires EU Responsible Person coverage.

Eldris allows multiple brands to operate under a single country onboarding appointment. The one-time fee of £195 per country covers your business entity, and all brands operating under that entity are included. Monthly pricing is based on total SKU count across all brands — not per brand. This makes Eldris particularly cost-effective for multi-brand operations that would otherwise face separate compliance arrangements for each brand identity.

Pricing

One-time onboarding: £195 per country, paid once, for life. Monthly base fee: £9.95. SKU tiers: up to 20 SKUs at £19.95 per month, up to 50 at £39.95, up to 250 at £99.95, up to 500 at £149.95, up to 1,000 at £199.95, and up to 2,000 at £249.95 with unlimited compliance. All brands under one entity operate under a single appointment.

The Compliance Chain You Need to Build

For service brands and white-label sellers, EU Responsible Person appointment is one link in a compliance chain. The complete chain requires your manufacturer or supplier to provide the underlying safety documentation — PIF, CPNP notification, Declaration of Conformity, or technical file depending on product type. Your business must ensure this documentation exists, is current, and is accessible. And your EU Responsible Person — Eldris — stands as the named EU contact who authorities can reach.

If any link in this chain is missing, your compliance position is compromised. Eldris cannot substitute for missing safety documentation from your supply chain. But Eldris can ensure that the EU Responsible Person link is active, compliant, and operational within one hour of onboarding — removing the single most common compliance gap that service brands and white-label sellers face when entering the EU market.