EAR Service Terms

X4JX LAB SL provides the EU Responsible Person service (European Authorized Representative, EAR), as required by Regulation (EU) 2023/988 of the European Parliament and of the Council on the General Product Safety Regulation (GPSR), applicable to all non-food products placed on the EU market from 13 December 2024.

This service is exclusively intended for manufacturers established outside the European Economic Area (EEA) who market or intend to market products in the European single market, including online sales channels. X4JX LAB SL, as an economic operator established in Spain (EU), coordinates the designation of EU Responsible Person before market surveillance authorities of the member states — directly or through its certified partner network when appropriate — assuming the formal obligations set out in Article 16 of the GPSR.

The EAR service is provided within the following regulatory framework: Regulation (EU) 2023/988 — GPSR (in force since Dec. 2024); Regulation (EC) 765/2008 on accreditation and market surveillance; applicable New Approach sectoral directives by product category; national EPR legislation: Verpackungsgesetz (DE), CITEO decree (FR), Ecoembes/Ecoembalajes (ES).

The client is responsible for ensuring their products comply with all applicable technical legislation in the destination member state. The role of X4JX LAB SL as EAR (or as coordinator of an EAR designated through its partner network) is legal representation, not technical product certification.

The external manufacturer (service client) undertakes to: (a) Provide X4JX LAB SL with all product technical documentation (DoC, Technical File, BOM, instruction manuals in relevant official languages) at least 30 days before launch; (b) Notify any substantial product modification that may affect its technical conformity; (c) Immediately notify any safety incident, end-user complaint or market surveillance authority requirement related to covered products; (d) Keep contact details and manufacturing establishment address current.

Failure to meet these obligations will relieve X4JX LAB SL of liability before market surveillance authorities and may result in immediate termination of the service.

As designated Responsible Person (directly or through its certified EU partner network), X4JX LAB SL undertakes to: (a) Appear (or coordinate the figure that appears) as EAR on product labelling and the Declaration of Conformity, providing legal name and physical address within the EU; (b) Maintain a copy of the complete technical documentation and DoC for 10 years from the last unit placed on the market, per Article 16.3 GPSR; (c) Cooperate with market surveillance authorities and provide requested documentation within 72 working hours; (d) Notify the client of any communication received from market surveillance authorities within 24 hours of receipt.

X4JX LAB SL maintains a professional liability insurance policy specifically to cover claims arising from its EAR coordination functions.

The EAR service is initially contracted for a 12-month period, automatically renewable for equal periods unless written notice is given by either party at least 30 days before the expiry date.

Either party may terminate the agreement early with 60 days' written notice. In case of termination, X4JX LAB SL will cooperate with the client to identify and appoint a new EAR before the effective termination date, ensuring continuity of regulatory coverage.

X4JX LAB SL's liability arising from the EAR service is limited to the amount of annual fees paid by the client in the 12 months prior to the event giving rise to liability, except in cases of wilful misconduct or gross negligence.

X4JX LAB SL maintains a professional liability insurance policy with minimum coverage of €2,000,000 per claim. The insurance certificate may be requested at legal@4jlab.com. This limitation clause does not affect the mandatory obligations set by the GPSR or the rights of third parties affected by product defects.