EU vs UK Authorised Representatives: What Changed After Brexit (2026 Update)

EU Authorised Representative: Essential Guides

• What is an EU Authorised Representative?
• Do I Need an EU Authorised Representative?
• EU vs UK Authorised Representatives after Brexit‍
• How to Choose an EU Authorised Representative

📥 Need help choosing the right EU Authorised Representative? Download our EU AR Selection Checklist to evaluate providers before signing a mandate.

Before Brexit, the UK sat inside the EU single market for goods. That meant one EU compliance framework applied across both the EU and the UK.

From 1 January 2021, the EU and the UK became two separate regulatory markets. The result wasn’t just new customs paperwork — it changed who is considered “established”, what markings apply, and which “economic operator” must be established in the market.

If you need a basic definition first, see What is an EU Authorised Representative? and if you’re unsure whether you need one, use Do I Need an EU Authorised Representative?

This guide explains what actually changed, who needs what today, and how to avoid paying for the wrong type of “representative”.

Quick answer (2026)

• EU/EEA: CE framework + EU economic operator rules; direct non-EU sellers often need an EU Authorised Representative (AR).
• Great Britain (GB): UK framework (UKCA), but CE remains accepted for many goods; you still need a UK-based economic operator (often the importer).
• Northern Ireland (NI): EU rules for many goods; CE remains central; UKNI only applies in specific conformity assessment routes.

What Changed on 1 January 2021

Brexit created two distinct compliance frameworks:

• EU market: EU legislation (CE marking where applicable) + EU rules on economic operators and market surveillance
• Great Britain (GB): UK legislation (UKCA framework, with continued acceptance of CE for many product areas) + UK economic operator obligations
• Northern Ireland (NI): continues to follow many EU rules for goods under the Windsor Framework (with specific NI marking rules in certain cases)

Before Brexit: One market, one framework

Until 31 December 2020, a manufacturer could generally rely on EU rules for the UK as well. A non-EU manufacturer selling across Europe could appoint an EU Authorised Representative (where required by the relevant EU product legislation) and operate across both the EU and UK under the EU framework.

After Brexit: Two markets, two frameworks

From 1 January 2021, the UK became its own regulatory market. You now need to think in three buckets:

1. EU (and EEA where applicable): EU rules
2. GB (England, Scotland, Wales): UK rules
3. NI: EU rules for many goods, with NI-specific marking mechanics in some cases

A critical correction: “UK Responsible Person” is not universal

Many articles online oversimplify this as: “EU needs an EU AR; UK needs a UK Responsible Person.” That is only true in certain product regimes.

In Great Britain, the core concept is the same as in the EU: economic operators (manufacturer / authorised representative / importer / distributor) have defined responsibilities under the relevant legislation.

For many CE/UKCA product regimes in GB, the key GB-based party is often the importer (unless the manufacturer appoints a UK authorised representative and mandates tasks).

The term “Responsible Person” exists in the UK mainly in sector-specific frameworks (notably cosmetics, medical devices, etc.). So in a general cross-category guide, it’s safer and more correct to say: GB requires a UK-based economic operator (often the importer, or sometimes a UK authorised representative, depending on the regime and your setup).

For a practical checklist on selecting the right EU-side operator, see How to Choose an EU Authorised Representative (12-point checklist).

UKCA vs CE: the transition that became “indefinite” (for many goods)

The UK introduced the UKCA marking for Great Britain after Brexit. But the UK government later stated it intends to continue recognising the CE marking in Great Britain indefinitely for most goods (with sector-specific exceptions).

So:

• EU/EEA: CE remains the route where applicable
• GB: UKCA is the UK framework, but CE is still accepted for many product areas
• NI: CE remains central under EU rules

Important: marking acceptance (CE vs UKCA) is not the same thing as economic operator obligations.

Quick Decision Guide: What do you need?

This section is intentionally “plain English”. Exact legal duties depend on product legislation. For a product-legislation-based decision tree (by sales model and supply chain), use Do I Need an EU Authorised Representative?

Scenario 1: You are established outside both the EU and the UK (e.g., US/China)

Selling in the EU only

• You need an EU-based economic operator.
• If you sell direct and no importer takes responsibility, that often means an EU Authorised Representative (and for some regimes it is explicitly required).
• GPSR also requires a “responsible economic operator” in the EU/EEA/NI for products in its scope.

Selling in Great Britain only

• You need a UK-based economic operator (often the GB importer; in some cases, a UK authorised representative can be used by mandate depending on the regime).
• Whether you use CE or UKCA (where CE is accepted) does not remove the need to have the correct GB economic operator setup.

Selling in both the EU and GB

• You typically need EU economic operator coverage (often EU AR for direct sellers) and a GB economic operator (often importer or UK authorised representative, depending on the model).

Scenario 2: You are established in the UK

Selling in the EU

• You are treated as a non-EU manufacturer for EU purposes and will need an EU economic operator solution (often EU AR for direct sales).

Selling in GB

• You are UK-established; the economic-operator model is satisfied by your establishment (but you still must meet the substantive UK requirements).

Selling in both

• You will need to manage EU-side economic operator requirements for EU sales and UK requirements for GB sales.

Scenario 3: You are established in the EU

Selling in GB

• You are a non-UK manufacturer for GB purposes. You typically need a GB economic operator in the chain (often an importer; sometimes a UK authorised representative structure).

Selling in the EU

• You are EU-established, so you generally do not need an EU AR.

Northern Ireland: the special case (don’t get this wrong)

Northern Ireland follows EU rules for many goods. UK government guidance explicitly notes that the Windsor Framework does not change which products require CE marking under EU rules in NI.

If you sell goods in Northern Ireland

• Treat NI as EU rules for many product categories: CE marking where applicable, EU compliance logic, and EU-side economic operator requirements. (GOV.UK)

UKNI marking (when it appears)

UKNI marking is used in specific cases involving mandatory third-party conformity assessment using a UK body for NI. (nibusinessinfo.co.uk)
(And products with UKNI marking are generally not placed on the EU market as “CE-only” goods.)

EU Authorised Representative: what remains true post-Brexit

The EU Authorised Representative concept still exists under EU product legislation and the EU market surveillance/economic operator framework.

A non-EU manufacturer placing regulated products on the EU market must ensure there is an EU-based economic operator. For many direct-to-consumer / marketplace models, the practical route is appointing an EU AR, especially where no importer is taking responsibility.

GPSR also requires a “responsible economic operator” with an address in the EU/EEA/NI for goods sold there.

Geographic coverage

An EU AR established in the EU can support EU-wide coverage for relevant legislation (and typically EEA where that legislation applies).

Great Britain: how the UK “representation” concept works

In GB, the UK guidance defines economic operators under relevant legislation as:
manufacturers (and authorised representatives), importers, distributors.

So the GB question is usually:

1. Who is the importer into GB?
2. Is the manufacturer appointing a UK authorised representative (where applicable) and assigning specific tasks?
3. Are the correct GB economic operator details available where required?

CE marking may still be accepted for many goods in GB, but the UK has its own framework and operator obligations.

Side-by-side comparison (high-level, cross-category)

Regulatory framework

• EU: EU legislation + CE where applicable
• GB: UK legislation + UKCA framework (with CE acceptance in many areas)
• NI: EU rules for many goods

Economic operator concept

• EU: economic operator required; AR used when no importer/manufacturer in the EU assumes responsibility
• GB: economic operators are manufacturer/authorised rep/importer/distributor
• NI: EU economic operator logic applies to many goods

Markings (simplified)

• EU: CE (where applicable)
• GB: UKCA or CE (CE accepted for many goods indefinitely per UK guidance)
• NI: CE (and in some cases CE+UKNI depending on conformity assessment route)

Key rule: CE vs UKCA relates to marking and conformity route. Economic operator obligations relate to who is established in the market and accountable. These are separate requirements.

Cost implications

Indicative only: service pricing varies by product category, SKU count, risk profile, and whether incident support is included. In GB, many businesses satisfy operator obligations via the importer (not necessarily a paid “UK representative” service).

Typical ranges (indicative)

• EU AR: €500–€3,000 / year
• UK-side economic operator support: often £400–£2,500 / year (where a service provider is used, e.g., UK authorised representative / sector-specific RP models)

If you sell in both markets and you’re using service providers on both sides:

• Combined: often lands around €1,200–€5,000 / year depending on service tiers and portfolio size.

(If you want, I can convert this section into a clearer pricing table aligned to your EcoComply packages.)

Common Brexit compliance mistakes

1. Assuming CE acceptance in GB means “no UK compliance needed”
   CE acceptance relates to marking; GB still has operator obligations and enforcement.
2. Treating Northern Ireland as “GB rules”
   NI follows EU rules for many goods - treat it separately.
3. Using pre-Brexit labelling and documentation everywhere
   EU and UK declarations, labels, and operator details can diverge by market.
4. Waiting for “final clarity” on UKCA
   UKCA timelines have shifted, but the need to structure responsibilities correctly in the supply chain is not optional.

Can one provider cover both the EU and the UK?

Yes, if the provider has legal establishment and operational capability in both jurisdictions.

Bundled service can reduce admin overhead and minimise mistakes during incidents, but only if the provider:

• understands your product legislation,
• has robust document systems,
• has realistic response SLAs,
• and can support market surveillance workflows on both sides.

What to do next

If you sell in the EU (or NI)

• Confirm whether you have the required EU/EEA/NI economic operator coverage (often EU AR for direct sellers; importer model for others).

If you sell in GB

• Identify who is the GB importer (or whether you need a UK authorised representative model for your regime).
• Decide on CE vs UKCA route per product category (where CE is still accepted).

If you sell in both

• Build a single “master technical file” with market-specific annexes (EU DoC vs UK DoC, standards references, certificates where applicable).
• Ensure labels/instructions support the correct operator details for each market.

The Bottom Line

Brexit created a permanent split: the EU and GB are separate compliance markets, and Northern Ireland follows EU rules for many goods.

The good news is that, for many products, technical requirements remain close — and the UK intends to keep recognising CE marking in GB for most goods indefinitely.
The key to avoiding unnecessary cost is getting the economic-operator structure right on each side, rather than buying a “representative” label that doesn’t match your product regime.

Lega references

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