EU Authorised Representative for CE-Marked Products
What Non-EU Manufacturers Need to Know
If you manufacture products outside the European Union and sell them into the EU market, appointing an EU Authorised Representative may be a legal requirement.
Many manufacturers assume that obtaining test reports, preparing a Declaration of Conformity, and applying the CE mark is enough. In reality, EU legislation often requires a designated economic operator established within the European Union who can communicate with authorities and maintain compliance documentation.
This article explains what an EU Authorised Representative is, when one is required, what responsibilities they have, and how to remain compliant when selling CE-marked products in Europe.
What Is an EU Authorised Representative?
An EU Authorised Representative is a natural person or legal entity established within the European Union that has received a written mandate from a manufacturer located outside the EU to perform specific compliance-related tasks on the manufacturer’s behalf.
The Authorised Representative serves as the manufacturer’s official contact point for EU market surveillance authorities and helps ensure that required documentation remains available when requested.
The Authorised Representative does not become the manufacturer. The manufacturer remains responsible for ensuring that the product complies with all applicable EU legislation.
Which Products Require an EU Authorised Representative?
Many CE-marked products sold by manufacturers located outside the European Union require an EU-based economic operator.
Common product categories include:
- Electrical and electronic products
- Radio equipment
- Machinery
- Personal protective equipment (PPE)
- Toys
- Medical devices
- Measuring instruments
- Construction products
- Low-voltage equipment
- Electromagnetic compatibility (EMC) products
The exact requirement depends on the applicable EU Directive or Regulation governing the product.
Regulation (EU) 2019/1020 and the Economic Operator Requirement
Since 16 July 2021, many products covered by EU harmonisation legislation may only be placed on the EU market if an economic operator is established within the European Union.
The economic operator may be:
- The manufacturer, if established in the EU
- The importer
- The Authorised Representative
- In some cases, a fulfilment service provider
For many non-EU manufacturers selling directly through e-commerce channels such as Amazon, Shopify, Etsy, or their own websites, appointing an EU Authorised Representative is often the most practical solution.
Appoint an EU Authorised Representative for CE-Marked Products:
Responsibilities of an EU Authorised Representative
The exact responsibilities depend on the applicable legislation and the written mandate provided by the manufacturer.
Maintaining Technical Documentation
The Authorised Representative must be able to provide the technical file, Declaration of Conformity, test reports, risk assessments, and supporting compliance documentation to market surveillance authorities upon request.
Cooperation With Authorities
Authorities may contact the Authorised Representative directly regarding compliance concerns, inspections, corrective actions, or product investigations. The Authorised Representative must cooperate and provide requested documentation.
Acting as an EU Contact Point
The name and address of the Authorised Representative are generally placed on the product, packaging, or accompanying documentation so authorities know whom to contact within the EU.
Supporting Corrective Actions
If safety concerns arise, the Authorised Representative may assist with communication regarding corrective actions, recalls, or product recalls.
Authorised Representative vs Importer
Many businesses confuse the role of the importer with that of the Authorised Representative.
An importer places products from a non-EU country onto the EU market and assumes specific legal obligations under EU law.
An Authorised Representative acts under a written mandate from the manufacturer and performs only the tasks delegated to them under applicable legislation. The Authorised Representative does not automatically become the importer and does not automatically assume importer responsibilities.
This distinction is particularly important for Amazon sellers, online retailers, and private-label brands.
What Information Must Appear on the Product?
For products requiring an EU Authorised Representative, authorities generally expect the following information to be available on the product, packaging, or accompanying documentation:
- Name of the Authorised Representative
- Registered business address within the EU
- Contact details where applicable
The exact placement requirements depend on the product category and applicable legislation. For general product safety information, manufacturers should also review the applicable labelling requirements for GPSR compliance.
What Happens if You Do Not Appoint an EU Authorised Representative?
Non-compliant products may face:
- Customs delays
- Product delistings from online marketplaces
- Requests from market surveillance authorities
- Product withdrawals
- Product recalls
- Financial penalties depending on the Member State
Authorities increasingly verify the existence of a valid EU economic operator when reviewing imported products.
How EaseCert Supports Non-EU Manufacturers
EaseCert supports manufacturers, importers, Amazon sellers, Shopify stores, and private-label brands with EU compliance requirements for CE-marked products.
Our EU Authorised Representative Service for CE-Marked Products helps manufacturers establish the required EU contact point and maintain access to the European market.
Our service includes:
- EU Authorised Representative appointment
- Technical documentation review
- Declaration of Conformity support
- Compliance guidance
- Market surveillance communication support
- Ongoing regulatory assistance
Whether you sell electrical products, machinery, toys, PPE, electronics, or other CE-marked products, our team can help establish the required EU presence and support your compliance obligations.
Frequently Asked Questions
What is an EU Authorised Representative?
An EU Authorised Representative (AR) is a person or company established within the European Union that has been formally appointed by a non-EU manufacturer to carry out specific compliance-related responsibilities on the manufacturer's behalf. The AR acts as a contact point for EU market surveillance authorities and maintains access to required compliance documentation.
Who needs an EU Authorised Representative?
Manufacturers located outside the European Union that sell certain CE-marked products into the EU may be required to appoint an EU Authorised Representative. The requirement depends on the applicable EU legislation governing the product category.
Is an EU Authorised Representative required for all CE-marked products?
Not always. Some CE-marking regulations require an Authorised Representative, while others only require an EU-based economic operator. The specific obligation depends on the product type and the applicable Directive or Regulation.
What is the difference between an EU Authorised Representative and an importer?
An importer places products from a non-EU country onto the EU market and assumes specific legal responsibilities. An Authorised Representative acts under a written mandate from the manufacturer and performs delegated compliance tasks but does not automatically assume importer responsibilities.
Can the EU Authorised Representative issue a CE Certificate or Declaration of Conformity?
No. The manufacturer remains responsible for product compliance, technical documentation, conformity assessments, and issuing the Declaration of Conformity. The Authorised Representative supports compliance activities but does not replace the manufacturer.
What documents must an EU Authorised Representative keep?
Depending on the applicable legislation, the Authorised Representative may need access to the Declaration of Conformity, technical file, test reports, risk assessments, user instructions, labeling information, and other supporting compliance documentation.
Does the Authorised Representative's address need to appear on the product?
In many cases, the name and address of the Authorised Representative must be displayed on the product, packaging, or accompanying documentation. Exact requirements depend on the applicable EU legislation and product category.
Can the same company act as both Authorised Representative and Responsible Person?
Yes, in some cases. However, the roles are governed by different regulations and responsibilities. An Authorised Representative typically supports CE-marked products under sector-specific legislation, while a Responsible Person may be required under frameworks such as the General Product Safety Regulation (GPSR).
What happens if I sell products in the EU without an Authorised Representative when one is required?
Products may be stopped at customs, removed from online marketplaces, withdrawn from the market, recalled, or become subject to enforcement action by EU authorities. Financial penalties may also apply depending on the Member State.
Can EaseCert act as my EU Authorised Representative?
Yes. EaseCert provides EU Authorised Representative services for eligible CE-marked products and supports manufacturers with technical documentation review, regulatory guidance, authority communication, and ongoing compliance support.
Need an EU Authorised Representative?
Final Thoughts
Selling CE-marked products in Europe requires more than applying a CE logo to the product. Manufacturers located outside the EU must ensure that all legal obligations are fulfilled, including the appointment of an EU-based economic operator where required.
An experienced EU Authorised Representative helps maintain compliance, provides a direct contact point for authorities, and supports smoother access to the European market.
If you are unsure whether your products require an EU Authorised Representative, EaseCert can review your product category and help determine the applicable requirements.
References
- Regulation (EU) 2019/1020 on Market Surveillance and Compliance of Products
- European Commission, Market Surveillance of Products
- Your Europe, CE Marking Overview
- Decision No 768/2008/EC on a Common Framework for the Marketing of Products
- Regulation (EU) 2023/988 on General Product Safety (GPSR)
- European Commission Safety Gate System
- European Commission, CE Marking Guidance