[Home](/)/[Resources](/resources)/EU Economic Operators EU complianceCE markingEU Authorised Representative # EU Economic Operators Explained: Who Is Responsible for CE Compliance? CE-marked products move through a chain of economic operators from production to end user. Each operator — manufacturer, EU authorised representative, importer, and distributor — carries specific legal obligations. Getting this structure right determines who is legally accountable when a product fails and whether authorities can act effectively against non-compliance. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Feu-economic-operators-explained) [Map my EU compliance responsibilities](/platform/new) Manufacturer ## Obligations and liability of the manufacturer The manufacturer bears primary responsibility for product compliance in the EU economic operator chain. Even when production is outsourced to a contract manufacturer, the legal manufacturer (the entity whose name appears on the Declaration of Conformity) bears the primary compliance obligation. The manufacturer must design and manufacture products that comply with all applicable essential requirements, draw up and maintain technical documentation for at least 10 years, perform conformity assessment, issue the EU Declaration of Conformity, apply the CE mark, and maintain post-market surveillance capabilities. Under GPSR (Regulation 2023/988), manufacturers must have documented internal complaint handling and recall capability. If the manufacturer is not established in the EU, they must appoint an EU Authorised Representative to act on their behalf for administrative compliance matters. EU Authorised Representative ## What an EU AR can and cannot do The EU Authorised Representative is a legal or natural person established in an EU member state, mandated in writing by the manufacturer to act on their behalf for CE compliance administrative matters. The EU AR is responsible for: holding a copy of the EU Declaration of Conformity and technical documentation at the disposal of market surveillance authorities for at least 10 years; cooperating with authorities on request; and forwarding information about non-compliant products to the manufacturer. Critically: the EU AR must be physically established in an EU member state — not in Switzerland, Norway, or other non-EU EEA members. Under Regulation 2019/1020, the manufacturer or their AR must be identifiable as the Article 4 responsible person capable of producing technical documentation within 72 hours of an authority request. Importer and Distributor ## The often-underestimated obligations of importers The EU importer — the entity that first physically brings a product from outside the EU into the EU market — must verify before placing a product on the market: that the manufacturer has drawn up technical documentation; that the product bears the CE mark and required markings; that the product is accompanied by required documents; and that the manufacturer has fulfilled their obligations. The importer must apply their own name, trade name, trademark, and postal address to the product or its packaging. This labelling obligation is regularly overlooked and frequently cited in market surveillance actions. Distributors who modify a product or market it under their own brand become the manufacturer for compliance purposes. ## Learn this properly, not just for one product In-depth courses and books that teach the process — not a one-off answer you'll need to look up again next time. [Browse courses](/courses)See your free roadmap [Prefer to read? Get the book](/books) ## Frequently asked questions ### Can the EU Authorised Representative sign the Declaration of Conformity? The DoC must be signed by the manufacturer or a person empowered to do so on behalf of the manufacturer. An EU AR can sign the DoC only if explicitly empowered to do so in their mandate — this must be a specific authorization, not just the general AR appointment. In practice, most DoCs are signed by the manufacturer, with the EU AR's details listed separately as the EU contact. ### What happens if a product has no identifiable EU economic operator? Market surveillance authorities can take action against online marketplaces that list products with no identifiable EU economic operator. Under GPSR and Regulation 2019/1020, platforms must cooperate with authorities to identify sellers. Products found without a traceable EU responsible party can be subject to mandatory market withdrawal, destruction, and public notification. ### Can the importer use the same entity as the EU Authorised Representative? The same legal entity can hold both roles if they meet the requirements for both. In practice, a single EU-based partner often serves as both the formal EU AR under specific directives and the importer who physically brings goods into the EU. The mandate agreement should clearly specify which obligations the entity is fulfilling in each capacity. ### Do distributors need to verify compliance documentation? Distributors must verify that the product bears the CE mark and required markings, is accompanied by required documents in the applicable language, and that the manufacturer and importer have fulfilled their obligations. They must cooperate with authorities and must not place products on the market if they have reason to believe they are non-compliant. 🇪🇺 CE Marking roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇪🇺 CE Marking compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Related guides * [EU Market Surveillance RegulationEU Regulation 2019/1020 strengthens market surveillance across all CE-marked product categories by expanding economic operator …](/guides/eu-market-surveillance-regulation) * [EU New Product Liability DirectiveNew EU PLD (2024/2853) expands liability to software, firmware updates, and AI.](/guides/eu-new-product-liability-directive) * [EU Supply Chain Due Diligence (CSDDD)The EU CSDDD (Directive 2024/1760) requires large companies to identify, prevent, and address adverse human rights and environm…](/guides/eu-supply-chain-due-diligence) * [CE Marking for Unintentional RadiatorsUnintentional radiators — digital devices that generate RF as a byproduct of operation — must comply with the EU EMC Directive.](/guides/ce-marking-unintentional-radiators) Educational resource only. Economic operator obligations vary by directive and product category. Verify requirements with qualified compliance professionals.