What is an EU Authorised Representative? Complete Definition & Role (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.

Quick answer

‍An EU Authorised Representative (AR) is a legal entity established in the EU appointed by a non-EU manufacturer via a written mandate to perform specific compliance tasks, typically holding technical documentation, providing it to market surveillance authorities on request, and cooperating with enforcement. The AR does not certify products and does not replace the manufacturer’s legal responsibility for compliance.

An EU Authorised Representative (EU AR) is far more than an address printed on a product label. For non-EU manufacturers, the AR is the formal legal interface between the manufacturer and EU market surveillance authorities. They hold and manage compliance documentation, respond to authority requests, and coordinate regulatory actions when safety issues arise.

Misunderstanding the AR role leads companies to:

• choose inadequate “mailbox” services,
• pay for services they don’t actually need, or
• assume compliance risks they don’t realise they carry.

EcoComply supports manufacturers (electronics, batteries, connected devices, industrial equipment) by structuring documentation into evidence packs and monitoring changes so AR mandates remain defensible over time.

This guide explains what an EU Authorised Representative legally is, what they are required to do, what they are not responsible for, and what actually happens when authorities get involved.

No sure if you legally need one → read Do I Need an EU Authorised Representative?

Want to choose the right one? → read How to choose EU AR (12-point checklist)

Legal Definition: What Is an EU Authorised Representative?

An EU Authorised Representative is a natural person or legal entity established in the European Union who is formally appointed by a manufacturer established outside the EU to perform specific tasks related to product compliance and market surveillance.

The AR is appointed via a written mandate and assumes defined legal obligations under applicable EU product legislation.

Key elements of the definition

“Established in the European Union”
The AR must be legally established in an EU Member State (or, where legislation applies, the EEA). This requires real establishment — not a PO box or virtual office.

“Acts on behalf of the manufacturer”
The AR represents the manufacturer in regulatory interactions with EU authorities.
Important: the manufacturer remains the primary party responsible for product safety and compliance.

“Written mandate”
There must be a formal, written legal agreement defining:

• which products are covered,
• which legislation applies,
• what tasks the AR performs,
• and how responsibilities are allocated.

Informal or verbal arrangements do not meet regulatory requirements.

“Defined legal obligations”
An AR is not a general business agent. Their duties are explicitly defined in EU legislation, and failure to perform them can trigger enforcement consequences.

What an EU Authorised Representative Is Not

Clarifying misconceptions is critical.

• Not an importer
  Importers place products on the EU market in their own name and assume importer obligations. ARs do not take ownership of products.
• Not a distributor
  Distributors buy and resell products. While a distributor can also be an AR, the roles are legally distinct and often best kept separate to avoid conflicts.
• Not a certification or testing body
  ARs do not test products, issue certificates, or approve compliance. That role belongs to test laboratories and Notified Bodies.
• Not optional if required
  Where EU law requires an EU-based economic operator and no importer assumes responsibility, appointing an AR is mandatory — not a “nice-to-have”.
• Not a mail-forwarding service
  Listing an address without an entity capable of performing AR duties does not satisfy legal requirements and often worsens enforcement outcomes.

Important clarification: EU rules require an EU-based economic operator for many regulated goods. Depending on your setup, that operator can be the EU manufacturer, the importer, an authorised representative, or in some models a fulfilment service provider entrusted with tasks. If there is no importer assuming obligations (common for direct-to-consumer models), appointing an AR is often the practical route.

The AR’s Core Responsibilities

For most of the time, a competent AR operates quietly in the background.
When something goes wrong, they become critical immediately.

Think of an AR like regulatory insurance: you hope never to need them urgently — but when you do, response speed and competence matter.

Responsibility 1: Hold and Maintain Technical Documentation

The AR must be able to make compliance documentation available to authorities without delay.

This typically includes:

• Technical file / technical documentation
• EU Declaration of Conformity
• Test reports and certificates
• Risk assessments
• Product specifications and drawings
• Manufacturing and quality documentation
• Instructions for use and safety information
• Labels and packaging details
• Change history and design modifications
• Complaint and incident records

Retention periods vary by legislation, but 10 years after the last product is placed on the market is common (longer for some product categories, such as medical devices).

“Hold and maintain” means:

• structured storage with version control,
• rapid retrieval,
• backup and security,
• and basic completeness checks.

A competent AR will flag missing or inconsistent documentation at onboarding, not when authorities request it.

Technical documentation (typical contents): EU Declaration of Conformity, test reports, risk assessment, design/spec documents, labeling/IFU, change history, complaint/incident log. The AR must be able to retrieve the correct version quickly and provide it to authorities within the requested deadline.

Responsibility 2: Respond to Market Surveillance Authorities

When authorities contact an AR, time is critical.

EU legislation generally requires cooperation without delay and within the timeframe specified by the authority, which is often short.

Common types of requests

• Routine compliance spot checks
• Complaint-triggered investigations
• Safety incident reviews
• Targeted market surveillance campaigns

What a competent response looks like

• Prompt acknowledgment of the request
• Timely submission of requested documentation
• Clear, structured responses
• Coordination with the manufacturer for clarifications
• Follow-up to confirm receipt and closure

What poor performance looks like

• Missed or delayed responses
• Incomplete files
• Inability to answer technical questions
• Language or communication barriers

When ARs fail here, authorities often assume non-compliance, which can trigger withdrawals, recalls, or public notices.

Responsibility 3: Support Corrective Actions and Recalls

If a safety issue arises, the manufacturer decides on corrective actions.
The AR implements and communicates those actions within the EU framework.

AR support typically includes:

• notifying relevant authorities,
• coordinating multi-country communication,
• helping prepare compliant recall notices,
• tracking progress and maintaining records.

Key distinction:
The AR does not decide whether a recall is necessary, but ensures EU procedures are followed correctly once a decision is made.

Responsibility 4: Maintain Complaint and Incident Records

ARs should maintain records of:

• consumer complaints,
• safety incidents or injuries,
• product failures or malfunctions,
• near-miss events.

These records help:

• identify emerging risks early,
• demonstrate due diligence if authorities investigate.

A well-kept incident log can significantly reduce regulatory escalation.

Responsibility 5: Communicate Relevant Regulatory Changes

Higher-quality AR services monitor regulatory developments and alert manufacturers when changes affect their products, such as:

• new or amended regulations,
• changes to harmonised standards,
• shifts in enforcement focus.

Example:
The General Product Safety Regulation (GPSR) was published in 2023 and became applicable in December 2024. Manufacturers with proactive ARs had time to adapt; others discovered gaps only after marketplace or authority action.

What an AR Does in Practice: Real Scenarios

Scenario 1: Routine Market Surveillance Check

French authorities request documentation for a Bluetooth speaker.

A competent AR:

• acknowledges quickly,
• compiles documentation,
• submits within the required timeframe,
• follows up until closure.

Outcome: compliance confirmed, sales continue.

Poor AR performance can lead to withdrawals and enforcement — even for compliant products.

Scenario 2: Consumer Complaint Escalation

A German consumer reports an overheating kettle.

A competent AR:

• coordinates incident reporting,
• submits documentation,
• supports investigation,
• helps authorities assess risk accurately.

Outcome: isolated incident, no market impact.

Scenario 3: Product Recall

A safety defect is discovered in a children’s toy batch.

A competent AR:

• coordinates notifications across affected countries,
• ensures recall notices meet EU requirements,
• tracks recall effectiveness,
• maintains regulatory records.

During recalls, an experienced AR is invaluable.

Scenario 4: Post-Brexit Transition

A UK manufacturer appoints an EU AR after Brexit.

A competent AR:

• reviews existing documentation,
• identifies gaps,
• supports relabelling,
• establishes ongoing compliance systems.

This is where many companies discover documentation weaknesses — better found early than by authorities.

Types of AR Services (Indicative)

Basic AR Service (€500–€800)

• Legal mandate
• EU address for labelling
• Secure document storage
• Authority response during business hours

Best for: low-risk, stable products with strong internal compliance.

Standard AR Service (€800–€1,500)

Includes Basic plus:

• regulatory update alerts,
• periodic documentation reviews,
• limited technical support,
• incident and recall coordination.

Best for: most SMEs selling regulated products.

Premium AR Service (€1,500–€3,000)

Includes Standard plus:

• dedicated compliance manager,
• priority response times,
• proactive surveillance monitoring,
• compliance gap analysis,
• Notified Body coordination.

Best for: high-risk categories or complex portfolios.

Enterprise AR Service (€3,000+)

Custom, multi-product, multi-category support for large manufacturers.

How the AR Mandate Works

The AR relationship is governed by a written mandate, which should clearly define:

• manufacturer and AR identification,
• scope of products and legislation,
• duties of both parties,
• liability allocation,
• documentation handling and retention,
• termination terms,
• data protection provisions.

Common mistakes:

• vague scope,
• unclear liability,
• no emergency procedures,
• no post-termination document transfer terms.

Never sign a mandate you don’t fully understand.

The AR’s Limitations

An AR cannot:

• make a non-compliant product compliant,
• perform testing or certification,
• redesign products,
• assume unlimited liability,
• prevent authorities from conducting checks.

Compliance remains the manufacturer’s responsibility. The AR enables compliance to be demonstrated and managed — not created.

Red Flags: When an AR may be Inadequate

• No proactive communication
• Poor understanding of your product regulations
• No documentation review before onboarding
• No demonstrable document management system
• Slow response times
• Lack of language capability

These are strong indicators of a mailbox service rather than a real AR.

What Makes a Good EU Authorised Representative

• Product-specific technical competence
• Stable EU establishment
• Robust documentation systems
• Clear, fast communication
• Multi-language capability
• Real market surveillance experience
• Proactive regulatory monitoring
• Professional liability insurance
• Transparent pricing and scope

The Bottom Line

An EU Authorised Representative is your legal voice in the EU product safety system.

Most of the time, they operate invisibly.
When authorities contact you, when incidents occur, or when regulations change, they become essential.

Choosing the right AR is not about price, it’s about competence, reliability, and response speed.

A quality AR costs little compared to the value of uninterrupted EU market access — and the cost of getting it wrong.

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Regulatory references (official guidance):

• Blue Guide 2022 (Commission Notice 2022/C 247/01) — economic operators & CE framework
• Regulation (EU) 2019/1020 — market surveillance & enforcement cooperation
• GPSR Regulation (EU) 2023/988 — responsible economic operator concept (for products in scope)

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