What is an EU Authorised Representative?

An authorised representative is a person or company in the EU that a manufacturer appoints, by written mandate, to carry out some of its compliance tasks. It is one of the economic operators recognised in EU product law, alongside the manufacturer, importer, distributor and fulfilment service provider.

The term matters most for brands based outside the EU. Since 16 July 2021, products under many CE-marking laws can only be placed on the EU market if an economic operator established in the EU is responsible for them. Since 13 December 2024, the General Product Safety Regulation (GPSR) extends the same rule to consumer products in general. Industry often calls this the EU responsible person.

The responsible economic operator

Article 4 of the Market Surveillance Regulation (EU) 2019/1020 sets the rule. The responsible economic operator must be one of:

1. a manufacturer established in the EU;
2. an importer, where the manufacturer is not established in the EU;
3. an authorised representative with a written mandate from the manufacturer;
4. a fulfilment service provider established in the EU, for the products it handles, but only where none of the others is established in the EU.

Article 4 covers products under the laws listed in its paragraph 5, such as the Toy Safety, Low Voltage, EMC, Radio Equipment and RoHS Directives and the PPE and Construction Products Regulations. Where an authorised representative takes the role, Article 5 requires its mandate to include the tasks below. GPSR Article 16 applies the same rule to products within the GPSR.

What the responsible person must do

Under Article 4(3) of Regulation (EU) 2019/1020, the responsible economic operator must:

• Check the paperwork. Verify that the EU declaration of conformity and technical documentation have been drawn up, keep the declaration available to authorities and make sure the documentation can be provided on request.
• Answer authorities. On a reasoned request, provide all information and documentation needed to show the product conforms, in a language the authority understands.
• Report risks. Inform market surveillance authorities when it has reason to believe a product presents a risk.
• Cooperate on corrective action. Make sure the necessary action is taken to fix non-compliance or reduce risks, for example a withdrawal or product recall.

For consumer products, GPSR Article 16(2) adds a duty to regularly check that the product matches its technical documentation and carries the required identification, contact details, instructions and safety information, and to give authorities evidence of those checks on request.

Name and address on the product

The responsible person's name, registered trade name or trade mark, and contact details, including the postal address (and, under the GPSR, the electronic address), must be shown on the product or its packaging, the parcel or an accompanying document. For online and distance sales, GPSR Article 19 requires the offer to show the manufacturer's details and, where the manufacturer is outside the EU, the responsible person's name and postal and electronic address.

Authorised representative, importer or fulfilment provider?

• Importer: buys and places the product on the EU market. It has its own legal duties and must put its own name and address on the product.
• Authorised representative: does not trade the product. It acts only within its mandate and must show a copy of the mandate to authorities on request. Under the GPSR (Article 10) and the Cyber Resilience Act (Article 18), the mandate must cover at least providing documentation to authorities and cooperating on risk-reduction action.
• Fulfilment service provider: offers at least two of warehousing, packaging, addressing and dispatching without owning the goods. It is the responsible person only as a last resort.

The manufacturer stays responsible for the product's design and conformity. Appointing a representative does not transfer those obligations.

How to prepare

1. Map your EU sales routes for each product: direct to consumer, through an EU importer, or through marketplaces and fulfilment centers.
2. Decide who the responsible person is for each route and product, and appoint an authorised representative by written mandate where no EU importer will take the role.
3. Give them the documents: declarations of conformity, technical documentation and test reports.
4. Update labels, packaging and listings with the responsible person's name and postal and electronic address.
5. Agree a process for authority requests, accident reports and recalls, so the responsible person can act quickly.