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# EU Authorised Representative: Who Needs One and How to Appoint

If you're a non-EU manufacturer selling CE-marked products into the EU, an Authorised Representative is not optional under most CE directives — it's a legal requirement. Without one, your product placement on the EU market is non-compliant from day one.

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At a glance

AR duty items

6

Mandate must-haves

7

FAQs

4

## Who needs an EU Authorised Representative?

### Non-EU manufacturer selling directly into the EU

Required. The AR acts as the legal contact point in the EU for market surveillance authorities.

### Non-EU company selling via an EU importer

The importer takes on importer obligations and is identifiable — an AR may still be needed depending on the directive and whether the importer's name appears on the product.

### EU-based manufacturer

Not required. EU manufacturers represent themselves directly.

### Non-EU company, non-CE product (GPSR only)

GPSR requires an EU-based responsible person to be contactable for consumer safety matters — this is a similar but distinct obligation from CE AR.

## What the AR is responsible for

01

Receive and respond to requests from market surveillance authorities on behalf of the manufacturer

02

Maintain a copy of the Declaration of Conformity and technical file (or ensure manufacturer access) for required retention period

03

Register products in EU databases where required (e.g., EPREL, EUDAMED) on the manufacturer's behalf

04

Forward complaints, incidents, and authority notifications to the manufacturer promptly

05

Cooperate with authorities in any corrective action, recall, or withdrawal procedures

06

Ensure the manufacturer's contact information and the AR's own details appear correctly on the product and documentation

## What an AR mandate must contain

*   Full legal names and addresses of both the manufacturer and the AR
*   List of specific products and CE directives covered by the mandate
*   Explicit grant of authority to act on behalf of the manufacturer for CE compliance purposes
*   Obligations of the AR as defined by each applicable directive
*   Duration of the mandate (or conditions for termination)
*   Signatures of both parties and date of execution
*   Governing law and jurisdiction clause

## Frequently asked questions

### Can the importer serve as the EU Authorised Representative?

Under most CE directives, the importer and the AR are legally separate roles. The importer has their own obligations (checking manufacturer compliance, adding their name to the product). The AR is specifically mandated by the manufacturer to act on their behalf. In practice, some companies offer combined importer/AR services — but the legal obligations under each role are distinct.

### What liability does an EU AR take on?

The AR's liability under CE directives is typically limited to their specific mandate obligations — primarily being reachable by authorities and maintaining documentation access. The manufacturer retains product liability and primary compliance responsibility. However, national product liability laws vary, and some AR agreements include indemnity clauses to manage shared risk.

### How do I find a qualified EU Authorised Representative?

AR services are offered by compliance consulting firms, product testing laboratories, and specialist regulatory service companies across the EU. Key criteria: experience with your specific product category and directives, clear mandate documentation, responsive communication process with authorities, and a track record of handling market surveillance interactions. Verify that the AR is based in the EU.

### Does the GPSR EU responsible person requirement replace the CE AR?

No — they are parallel obligations. The GPSR EU responsible person requirement (from December 2024) is separate from CE directive AR obligations. A company can use the same entity for both, but the mandate must explicitly cover both roles under both legal frameworks.

**Disclaimer:** Educational resource only. Not legal advice. AR requirements vary by directive. Always verify the specific obligations under each applicable directive before appointing a representative.

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