What is an EU Authorised Representative?

Introduction to EU Authorised Representative

An EU Authorised Representative is a natural or legal person explicitly designated by a manufacturer located outside the European Economic Area (EEA) (including the EU and EFTA). This person or entity can represent the manufacturer from outside the EEA to fulfill specific responsibilities required by EU directives and laws.

According to the EU's new product safety regulation, the Market Surveillance Regulation (EU) 2019/1020, starting from July 16, 2021 (local time), most products with the CE mark in the EU (except the UK) require an EU Authorised Representative as a point of contact for product compliance. E-commerce sellers in EU countries have also received emails from Amazon, requiring sellers with CE-marked products to upload EU Authorised Representative information on time, or else their products may not pass customs, product pages may not display, or non-compliant products could even be removed from the platform.

Why is an EU Authorised Representative Needed?

To ensure the safety of products sold within the EU market and to ensure that CE-marked products imported from outside the EU comply with EU laws and regulations related to consumer, property, and environmental protection, EU law requires manufacturers outside the EU to appoint an EU Authorised Representative based within an EU + EFTA member state. This representative is tasked with dealing with European authorities and agencies on behalf of the manufacturer.

What Are the Responsibilities of an EU Authorised Representative?

1. Ensure product compliance with all applicable EU regulatory requirements and maintain the Declaration of Conformity (DOC) and technical documentation.

2. Provide all relevant product information to authorities in a language they understand when requested.

3. Proactively report any potential risks to regulatory authorities when identified.

4. Work with authorities to implement corrective actions for non-compliant products.

Which Products Require an EU Authorised Representative?

Any product that bears the CE mark requires an EU Authorised Representative. Currently, most products in the EU market must bear the CE mark. According to EU regulations, products such as:

- Electronics

- Medical devices

- General consumer goods

- Building materials

must include the EU Authorised Representative (EC REP) information on their packaging and instructions.

How to Apply for an EU Authorised Representative?

The representative must meet one of the following criteria:

1. The manufacturer is located within the EU.

2. The importer (in cases where the manufacturer is outside the EU).

3. An authorised representative established within the EU (appointed in writing by the manufacturer, to perform responsibilities on behalf of the manufacturer and provide the authorisation to market surveillance authorities when required).

4. Service providers of the product, such as e-commerce platforms.

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What Are the Consequences of Not Appointing an EU Authorised Representative?

1. Selling CE-marked products on Amazon in Europe without an EU Authorised Representative will be considered illegal. Amazon conducts periodic checks, and products found non-compliant will face penalties.

 Recently, some sellers faced malicious complaints from competitors, leading to product removal, causing unnecessary trouble and losses. Therefore, sellers who meet the requirements should comply as soon as possible.

2. When there are customs clearance issues with products from non-EU exporters, the EU Authorised Representative helps communicate with customs and resolve problems. Customs authorities typically require communication with the exporter’s EU Authorised Representative. The EU Authorised Representative will also assist in resolving issues if products face any problems during the sales process in the EU. Therefore, the EU Authorised Representative assumes certain risks—the higher the risks associated with the exported products, the higher the risks the EU Authorised Representative bears.

3. EU customers require non-EU exporters to provide EU Authorised Representative information to ensure product quality and the exporter’s credibility, as well as to facilitate future communication.