How to Choose an EU Authorised Representative (AR): 12-Point Checklist (2026)

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.

Your EU Authorised Representative (AR) can be the difference between a smooth market surveillance interaction and a painful scramble when an authority asks for files.

But let’s make one thing precise up front:

• An AR does not “keep you compliant” by themselves - the manufacturer remains responsible for product compliance.
• What the AR does is ensure there is a competent, EU-established economic operator who can make required documentation available and cooperate with authorities when requested. That’s a core theme in EU product rules and market surveillance.

‍Quick answer

To choose an EU Authorised Representative (AR), verify three things first:

‍(1) they are legally established in the EU and can sign a compliant mandate,

‍(2) they have a written process to handle market surveillance requests under short deadlines,

‍(3) they can store and retrieve the correct technical documentation version fast (traceability).

Use the 12-point checklist below to avoid ARs that only sell an “address.”

Definition

An EU Authorised Representative (AR) (also written "Authorized representative") is an economic operator established in the EU appointed by a manufacturer through a written mandate to perform specific compliance-related tasks (typically document availability and authority cooperation). An AR does not replace the manufacturer’s responsibility for compliance.

What’s really at stake

When things go right

Your AR:

• keeps your documentation organised and retrievable,
• supports updates and document control,
• responds professionally to authority requests,
• and you rarely notice them.

When things go wrong

What changes is speed and competence:

• a market surveillance authority requests technical documentation (deadlines are often short and set by the authority),
• a consumer complaint triggers an investigation,
• a platform asks you to evidence your EU economic operator setup,
• or a defect requires coordinated corrective action.

A small difference in annual fees can become irrelevant if your AR can’t respond properly when it matters.

If you’re not sure whether you legally need an AR (or an importer can cover the role), start with Do I Need an EU Authorised Representative?

EcoComply works primarily with electronics, batteries, connected devices (IoT), innovative industrial equipment, and personal equipment - categories where market surveillance requests often require fast traceable evidence packs.

Important

‍An EU Authorised Representative is not the same as an Importer, Distributor, or a “Responsible Person.” The manufacturer remains responsible for compliance; the AR supports market surveillance cooperation and document availability based on a written mandate.

The 12-point AR selection checklist

1) Technical competence in your product category

What to verify

• They understand the product legislation that typically applies to your category (e.g., RED/EMC/LVD for electronics, toys rules for toys, etc.).
• They can explain what documentation is normally expected and how it’s structured.

Why it matters
The “Blue Guide” makes clear that an AR cannot “fix” compliance or create technical documentation in place of the manufacturer unless legislation provides otherwise. Your AR must know what they can and cannot do - and what they must hold and provide.

How to test
Ask:

• “What would you expect to see in our technical documentation?”
• “What are the common gaps you see for our category?”

Red flag
They claim to be experts in “everything” but can’t speak concretely about your category.

2) Written response process (not vague promises)

What to verify

• A written procedure for authority requests: intake, acknowledgement, internal escalation, document retrieval, submission, follow-up.
• A realistic service commitment (SLA) for acknowledgement and submission.
• Ask the AR to show a sample timeline of an authority request: acknowledgement, internal escalation, document retrieval, submission, follow-up.

Why it matters
Authorities can request documentation and expect cooperation “without delay” and within the timeframe they set. Don’t hard-code “48 hours” in your marketing unless your AR contract guarantees it - and even then, authorities may set different deadlines.

Red flag
“We respond as quickly as possible” with no written process.

3) Document management that supports rapid retrieval

What to verify

• Structured storage, version control, backups, and access controls.
• Ability to retrieve the correct version quickly.
• Clear policy for document updates and change history.

Why it matters
EU guidance expects technical documentation to be prepared and made available to market surveillance authorities upon request, and typically retained for 10 years unless the specific legislation says otherwise.

Avoid over-claims
Don’t require “ISO 27001 certification” as a universal legal must-have. It’s a nice-to-have, not a legal condition for being an AR.

Red flag
They won’t explain (at a high level) how documents are stored, protected, and retrieved.

4) Genuine EU establishment and verifiable legal identity

What to verify

• They are established in the EU (real legal entity; verifiable company registration).
• They can provide the information you need for your mandate and labelling.

Why it matters
EU rules require the AR to be established in the Union; “virtual office” style setups often fail scrutiny.

Correction
Don’t make “EORI number” a blanket requirement for ARs. EORI is relevant for customs/economic operators in certain contexts, but it’s not a universal AR qualification criterion.

Red flag
They won’t share business registration details that you can verify.

5) Language capability aligned to your sales footprint

What to verify

• Ability to communicate effectively with authorities in the markets you sell into.
• At minimum: strong English plus capability for major EU languages, depending on your exposure.

Why it matters
Authorities often work in national languages. A professional AR should be equipped to handle that.

Red flag
“English-only, covers all EU member states,” with no practical plan.

6) Clean conflicts of interest

What to verify

• If the AR is also your distributor/importer: clear separation of compliance duties vs commercial incentives, documented in the mandate or associated agreements.

Why it matters
Commercial partners can have incentives to delay or downplay corrective actions. That doesn’t automatically disqualify them - but you need governance.

Red flag
AR is bundled into a sales deal, and documentation access/control becomes unclear.

7) Understanding of the GPSR “responsible economic operator” logic

What to verify

• They can explain how the GPSR framework works for consumer products in scope: a responsible economic operator in the EU can be an EU manufacturer, importer, authorised representative, or fulfilment service provider entrusted with tasks related to safety.

Why it matters
Many brands confuse “AR” with “GPSR responsible person”. Under GPSR, the concept is the responsible economic operator, and AR can be one route, but not the only one.

Red flag
They market “GPSR solved” without clarifying what role they play and what tasks are actually covered.

8) Real market surveillance experience (not theory)

What to verify

• They have handled actual authority requests and can describe the workflow (anonymised).
• They understand what triggers scrutiny in your category.

Why it matters
Practice matters. Regulation isn’t hard to quote; execution under a deadline is hard to do.

Red flag
They claim they can “prevent authorities from contacting you.” Nobody can guarantee that.

9) Corrective action and recall coordination capability

What to verify

• Written incident escalation and corrective action coordination procedures.
• Ability to support multi-country communications and recordkeeping.

Why it matters
In a real incident, you need speed, documentation discipline, and clear coordination.

Careful wording
Avoid claiming your AR “manages recalls end-to-end” unless your contract truly includes those services and scope.

10) Transparent pricing and scope

What to verify

• What’s included (products, categories, SKUs, document reviews, authority responses).
• What costs extra (new categories, major revisions, translations, incident support, after-hours coverage).

Why it matters
The biggest cost surprises come from “low base fee + everything else extra”.

Red flag
No fee schedule in writing.

11) Track record and insurance (as a risk-control tool)

What to verify

• References from similar industries.
• Professional liability / E&O insurance (not always legally required, but a strong indicator of seriousness).

Red flag
No references, no proof of operational maturity.

12) Exit terms and document ownership

What to verify

• You retain ownership of your technical documentation.
• Clear termination and handover procedure (to you or a new AR).
• No hostage-style “transfer fees”.

Why it matters
If you ever switch providers, your compliance continuity depends on clean transfer.

Red flag
They claim they “own” your files.

Five red flags that should disqualify an AR

1. Can’t provide verifiable business registration
2. No written mandate / unwilling to sign a proper mandate (mandate is a core legal concept)
3. Mailbox-only setup with no operational capability
4. No documented process for authority requests
5. Claims they can guarantee approvals or prevent enforcement (not credible)

Practical questions to ask on the first call

• “Show me your onboarding checklist. What do you verify before accepting a mandate?”
• “How do you handle document updates and version control?”
• “Walk me through a real authority request you handled (anonymised).”
• “What’s included in your annual fee, and what triggers extra charges?”
• “If we terminate, what’s the exact transfer process and timeline?”

The Bottom Line

Choosing an EU Authorised Representative is not about buying an address. It’s about appointing an EU-established economic operator who can hold and make available the required compliance documentation and cooperate with authorities when needed.

Use the checklist above to choose based on:

• capability under pressure,
• documentation discipline,
• clear scope and pricing,
• and a clean legal establishment.

Legal references:

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