[Home](/)/[Resources](/resources)/UKCA Authorised Representative United KingdomUKCACompliance # UKCA Authorised Representative: Who Needs One and How to Appoint Overseas manufacturers placing products on the Great Britain market under UKCA-framework regulations must appoint a UK Authorised Representative where expressly required by the relevant statutory instrument. The UKAR holds legal compliance responsibility — holding technical documentation, cooperating with OPSS, and being named on the Declaration of Conformity — without necessarily being the commercial importer. Getting the appointment right is foundational to lawful market access. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fuk-ukca-authorised-representative) At a glance UKAR required for Non-UK manufacturers on GB market GB market authority OPSS (Office for Product Safety and Standards) Windsor Framework note CE marking still accepted in Northern Ireland Key AR obligation Hold technical documentation for 10 years ## UKCA Authorised Representative — key concepts ### Who Must Appoint a UK Authorised Representative A manufacturer established outside the United Kingdom who places products on the Great Britain market (England, Scotland, Wales) under UK regulations must appoint a UK Authorised Representative (UKAR) where the relevant product regulations expressly require one. The UKAR obligation is regulation-specific — it arises under the UK Electrical Equipment (Safety) Regulations 2016, the UK Radio Equipment Regulations 2017, the UK Toys (Safety) Regulations 2011, and other UKCA-framework regulations, but not uniformly across all product categories. The key test is whether the specific statutory instrument covering the product mandates an AR. ### GB Market vs Northern Ireland — Windsor Framework The Great Britain market (England, Scotland, Wales) requires UKCA marking under UK regulations, with overseas manufacturers needing a UK AR where applicable. Northern Ireland operates under a distinct regime: under the Windsor Framework (previously the Northern Ireland Protocol), Northern Ireland continues to apply EU product law — CE marking is accepted and EU Authorised Representatives remain relevant. Products placed on the Northern Ireland market by a manufacturer established outside the UK and EU may require an EU AR rather than, or in addition to, a UKAR depending on the product's regulatory framework and supply chain routing. ### UKAR Legal Obligations The UK Authorised Representative's obligations are set out in each relevant product regulation but typically include: holding or having access to the Declaration of Conformity and technical documentation for at least ten years from the last date of manufacture; being named and addressed on the product, packaging, or accompanying documentation; cooperating with the Office for Product Safety and Standards (OPSS) and providing all information and documentation necessary for the investigation of product safety concerns; taking corrective action if a safety issue arises; and notifying the OPSS of known non-compliant products placed on the market. ### UKAR vs Importer — A Critical Distinction An importer acquires commercial title to goods and places them on the market in their own name — they bear economic risk and take margins. The UKAR holds legal compliance responsibility without necessarily being commercially involved in the supply chain: they do not need to take title to goods, handle shipments, or carry stock. Many overseas manufacturers appoint a commercial UKAR service provider — a specialist AR firm — that accepts the legal mandate without being the trading importer. Where a UK importer is willing to assume the UKAR mandate in addition to their trading role, the same entity can serve both functions. ### The UKAR Appointment Mandate The UKAR appointment must be documented in a written mandate signed by both the manufacturer and the UKAR. The mandate must at minimum: identify the products covered by product name, model, or range; specify the period of appointment; record the UKAR's agreement to assume the obligations prescribed by the relevant regulations; and grant the UKAR access to the technical documentation and Declaration of Conformity. OPSS may request sight of the mandate during an investigation; a missing or incomplete mandate undermines both the UKAR's standing and the manufacturer's market access compliance. ### UKAR Liability Exposure The UKAR is not the manufacturer and does not design or produce the product. However, by accepting the mandate, the UKAR takes on statutory obligations and can face enforcement action by OPSS if those obligations are not met. In some regulatory frameworks — particularly where the UKAR is required to sign the Declaration of Conformity — the UKAR assumes joint and several liability for product compliance alongside the manufacturer. Commercial UKAR service providers typically require the manufacturer to indemnify them against product liability and recall costs, and will carry professional indemnity insurance as a minimum. ## Appointing a UKCA Authorised Representative: step by step 01 Identify the specific UK statutory instruments that govern each product placed on the GB market — regulations such as SI 2016/1101 (Electrical Equipment Safety) or SI 2017/1206 (Radio Equipment) — and confirm whether each regulation expressly requires a UK Authorised Representative for non-UK manufacturers. 02 Confirm whether the manufacturer has a UK establishment. A manufacturer with a registered office or principal place of business in the United Kingdom does not need to appoint a UKAR — the UKAR obligation applies only to manufacturers established entirely outside the UK. 03 Select a UKAR: this may be a commercial AR service provider, a UK subsidiary of the manufacturer, or a UK distributor willing to accept the mandate. Assess their capacity to hold or access the technical documentation and respond to OPSS within required timeframes. 04 Draft and execute a written UKAR appointment mandate specifying the products covered, the period of appointment, the UKAR's obligations, and the process for the manufacturer to supply updated technical documentation and incident reports to the UKAR. 05 Ensure the UKAR's name and UK address appear on the Declaration of Conformity and on or with the product as required by the specific regulation. Update product labelling, packaging, and documentation before shipment to GB. 06 Provide the UKAR with the complete technical documentation — including the risk assessment, test reports, circuit diagrams, and Bill of Materials — and establish a procedure for notifying the UKAR of any post-market safety incidents, product modifications, or regulatory changes. 07 Monitor OPSS guidance on UKAR obligations as the UK UKCA framework continues to develop post-Brexit, including any updates to market surveillance and enforcement priorities published by OPSS at gov.uk/government/organisations/office-for-product-safety-and-standards. ## Frequently asked questions ### Does every overseas manufacturer selling in the UK need a UKCA Authorised Representative? No — the UKAR requirement is regulation-specific, not a blanket rule. It applies under each product regulation that expressly mandates it. UK regulations modelled on EU product safety directives — such as the UK Low Voltage Directive equivalent (Electrical Equipment Safety Regulations 2016) and the UK Radio Equipment Regulations 2017 — require a UKAR for non-UK manufacturers. Other product categories may only require the name and address of the UK importer. Always check the specific SI covering your product. Where no UKAR obligation exists, an importer who places goods on the GB market on their own behalf satisfies the supply chain compliance requirements. ### Can the same company be both the UK importer and the UKCA Authorised Representative? Yes. There is no prohibition on a single UK entity holding both roles simultaneously. A UK distributor or subsidiary that imports goods from an overseas manufacturer can enter into a UKAR appointment mandate with that manufacturer, accepting the AR obligations, while also acting as the commercial importer that places the product on the GB market. The combined role must be clearly documented: the entity must be named on the Declaration of Conformity as the UKAR, and the UKAR mandate must be executed separately from any commercial distribution agreement. This combined-role approach is common in UK electronics distribution. ### What is the difference between a UKCA AR and an EU Authorised Representative? A UKCA Authorised Representative is appointed under UK regulations and is responsible for market access on the Great Britain market. An EU Authorised Representative is appointed under EU product directives and regulations and covers the 27 EU member states. They are legally distinct roles under separate regulatory frameworks. Since Brexit, neither EU AR status nor UKCA AR status is mutually transferable — an overseas manufacturer placing products on both markets typically needs both. Northern Ireland is a special case: under the Windsor Framework, CE-marked products remain accepted in Northern Ireland, meaning the EU AR covers Northern Ireland indirectly. ### What liability does a UKCA Authorised Representative take on? The UKAR's liability is primarily regulatory — OPSS can investigate and take enforcement action against a UKAR that fails to cooperate, fails to hold required documentation, or fails to notify OPSS of known non-compliant products. In product liability terms, a UKAR who is not also the importer does not automatically become a 'producer' under the Consumer Protection Act 1987 purely by virtue of the AR mandate — the producer analysis depends on whether the UKAR holds out the product as their own or first imports it. However, in some product regulations the UKAR's signature on the Declaration of Conformity creates a statutory duty whose breach can be enforced. Commercial UARs always seek manufacturer indemnities and carry appropriate insurance. **Disclaimer:** Educational resource only. UK regulatory requirements change. Consult a qualified UK solicitor or compliance specialist before making decisions. 🇬🇧 UK roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/09-ukca-marking-for-electronics-products)[Prefer to read? 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