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The authorised representative role in EU product compliance

An authorised representative is a company established in the EU that holds a written mandate from a manufacturer to act on the manufacturer's behalf for specified tasks. The mandate must at least let it give the authorities documents, report risks and cooperate on corrective action. Under the CE acts, design and manufacture in conformity and drawing up the technical documentation stay with the manufacturer. For a manufacturer outside the EU, the representative is often also the responsible person in the EU.

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Reviewed 5 October 2026 by the Conphora compliance team · Not legal advice

Am I the authorised representative?

What the law asks of you

The references name the General Product Safety Regulation (GPSR) and, as the example of a CE act, the Low Voltage Directive (LVD). For products under a product-specific harmonisation act, such as the Low Voltage or Toy Safety Directive, the GPSR's Chapter III, Section 1 (Articles 9 to 18) does not apply, and the act's own duties take its place (Article 2(1), third subparagraph, point (b)). The GPSR's safety requirement still covers risks the act does not (point (a)), and Articles 19 to 22, on online offers, accidents and online marketplaces, apply to all products, as do the recall rules in Articles 35 to 37. REACH restrictions and labelling rules do not take a product out of Articles 9 to 18. Whoever places on the EU market a product not designed for it, or a used product from outside the EU, takes on the manufacturer's role (Blue Guide, section 3.1); a used CE product resold inside the EU falls under the GPSR in full. The regulation guides list the article for each act.

Before the product is placed or sold

  • Act only under a written mandate from the manufacturer that sets out the tasks you perform on its behalf, and for the products it covers. GPSR Art. 10(1); LVD Art. 7(1); Regulation (EU) 2019/1020 Art. 5(1)
  • Under the Low Voltage Directive, the manufacturer's duty to design and manufacture in conformity and its duty to draw up the technical documentation cannot form part of the mandate; the other CE acts follow the same pattern. The GPSR lists the minimum tasks of a mandate and names no excluded ones. LVD Art. 7(1); GPSR Art. 10(2)
  • Have the appropriate means to fulfil your tasks. Regulation (EU) 2019/1020 Art. 5(3)

On the product and in the offer

  • Where the mandate makes you the economic operator responsible for the product, your name, registered trade name or registered trade mark and your contact details go on the product, its packaging, the parcel or an accompanying document: the postal address under Regulation (EU) 2019/1020, the postal and electronic address under the GPSR. Regulation (EU) 2019/1020 Art. 4(4); GPSR Art. 16(3)

Records to keep

  • Under the Low Voltage Directive, keep the EU declaration of conformity and the technical documentation at the disposal of the market surveillance authorities for 10 years after the equipment was placed on the market. LVD Art. 7(2)(a)
  • Provide a copy of the mandate to the market surveillance authorities on request. GPSR Art. 10(2); Regulation (EU) 2019/1020 Art. 5(2)

While it is on the market

  • On a reasoned request, give the authority all information and documentation needed to demonstrate the safety or conformity of the product, in an official language that authority understands. GPSR Art. 10(2)(a); LVD Art. 7(2)(b)
  • Where you are the responsible operator for a product under the GPSR, check regularly that the product matches its technical documentation and carries the required identification, contact details and instructions, and keep evidence of the checks. GPSR Art. 16(2)

When something is wrong

  • Inform the manufacturer when you consider or have reason to believe that a product is dangerous, and notify the authorities through the Safety Business Gateway of action taken to eliminate the risks where the manufacturer has not done so. GPSR Art. 10(2)(b) and 10(2)(c)
  • Cooperate with the authorities, at their request, on any action taken to eliminate the risks posed by the products covered by your mandate. GPSR Art. 10(2)(d); LVD Art. 7(2)(c)
  • Where you are the responsible person for a product whose manufacturer is outside the EU, make sure that an accident you know of is notified through the Safety Business Gateway. This applies to CE products too. GPSR Art. 20(4)

An authorised representative is defined by its mandate. The General Product Safety Regulation (EU) 2023/988 defines it as a person established within the Union who has received a written mandate from a manufacturer to act on the manufacturer's behalf in relation to specified tasks (Article 3(9)). The mandate must allow the representative to perform at least four tasks: providing an authority, on a reasoned request, with the information and documentation necessary to demonstrate the safety of the product; informing the manufacturer where it has reason to believe a product is dangerous; notifying the authorities through the Safety Business Gateway of action taken to eliminate risks, where the manufacturer has not done so; and cooperating with the authorities on such action (Article 10(2)).[1]

The CE acts have their own article, and for products they cover Chapter III, Section 1 of the GPSR (Articles 9 to 18) does not apply (Article 2(1), third subparagraph, point (b)). Under the Low Voltage Directive 2014/35/EU, the mandate must allow the representative at least to keep the EU declaration of conformity and the technical documentation at the disposal of authorities for 10 years, to provide information and documentation on a reasoned request, and to cooperate on action to eliminate risks (Article 7(2)). The obligation to design and manufacture in conformity and the obligation to draw up the technical documentation do not form part of the mandate (Article 7(1)). The Commission's Blue Guide describes the delegable tasks as administrative and notes that the representative cannot modify the product on its own initiative.[3][4]

A second, separate role is the responsible economic operator. A product under the acts listed in Article 4(5) of Regulation (EU) 2019/1020, or covered by the GPSR, may be placed on the market only if an operator established in the Union is responsible for the tasks in Article 4(3) (Article 4(1); GPSR Article 16(1)). An authorised representative fills this role only when the written mandate designates it to perform those tasks (Articles 4(2)(c) and 5(1)).[1][2]

The representative's own duties are few but firm. It performs the tasks in the mandate, provides a copy of the mandate to authorities on request, and must have the appropriate means to fulfil its tasks (Regulation (EU) 2019/1020, Article 5(2) and (3)). The manufacturer does not shed responsibility by appointing one: the Blue Guide states that a manufacturer may in no circumstances discharge itself of its responsibilities to an authorised representative.[2][4]

What Conphora does for the authorised representative

What the platform does today for a company in this role.

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Who you share with

  • Manufacturer

    You give
    Requests from authorities, and word when you have reason to believe a product is dangerous.
    You receive
    The written mandate with the products and the tasks, the declaration of conformity and access to the technical documentation.

  • Importer

    You give
    Your name and contact details where you are the responsible operator, for the label and the offers.
    You receive
    Complaints and accident information that concern the products under your mandate.

  • Market surveillance authorities

    You give
    A copy of the mandate, the declaration and the technical documentation on request, and cooperation on corrective action.
    You receive
    Reasoned requests and orders for corrective action.

See the whole flow →

Regulations that bind the authorised representative

Taken from the regulation guides: 33 acts name this role. The article numbers are those of the role's duties in each act.

and 21 more in the regulation library · All regulation guides →

Problems people in this role ask about

Problem pages written for this role: 1 in all.

We want to appoint an authorised representativeRoles and responsibilities

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Questions about the role

Must a manufacturer outside the EU have an authorised representative?

The Blue Guide says a manufacturer outside the Union is not obliged to have one. What the GPSR and the CE acts listed in Article 4(5) of Regulation (EU) 2019/1020 require is an economic operator in the Union responsible for the product: an importer can fill that role, an authorised representative with a written mandate is the alternative, and a fulfilment service provider in the Union fills it where neither exists. Some acts outside that framework do require a representative, for example the Medical Devices Regulation (EU) 2017/745 (Article 11).

Can a distributor or an importer be the authorised representative?

Yes, with a written mandate. The Blue Guide notes that the representative may be an importer or distributor, which must then also fulfil the obligations of that role. A commercial representative or agent without such a mandate is not an authorised representative in the legal sense.

Can the representative draw up the technical documentation?

Not under the Low Voltage Directive: the manufacturer's duty to design and manufacture in conformity and the duty to draw up the technical documentation cannot form part of the mandate (Article 7(1)). Other acts follow the same pattern; check the article on authorised representatives in each act.

Can the representative sign the declaration of conformity?

Depending on the act, yes. The Blue Guide lists drawing up and signing the EU declaration of conformity and affixing the CE marking among the tasks a mandate can include. The manufacturer remains responsible for the content.

Is the authorised representative the same as the responsible person in the EU?

Not automatically. They are separate appointments with different minimum tasks. An authorised representative fills the role of responsible economic operator only when the written mandate designates it to perform the tasks in Article 4(3) of Regulation (EU) 2019/1020 (Articles 4(2)(c) and 5(1)). One written mandate can cover both: the tasks under the product's own act and the Article 4(3) tasks, as the Blue Guide notes (section 3.2).

Is the authorised representative liable for the product?

Under the GPSR it performs the tasks in its mandate, and the manufacturer keeps the manufacturer's obligations. Liability for damage is a separate matter: for products placed on the market or put into service from 9 December 2026 whose manufacturer is outside the Union, Directive (EU) 2024/2853 makes the authorised representative liable alongside the manufacturer and the importer, as national law transposing it provides (Articles 2(1) and 8(1)(c)(ii)).

Sources

  1. Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026) EUR-Lex · accessed 5 October 2026
  2. Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026) EUR-Lex · accessed 5 October 2026
  3. Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026 EUR-Lex · accessed 5 October 2026
  4. The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01) European Commission, via EUR-Lex · accessed 5 October 2026
  5. Decision No 768/2008/EC on a common framework for the marketing of products EUR-Lex · accessed 5 October 2026
  6. Directive (EU) 2024/2853 on liability for defective products EUR-Lex · accessed 5 October 2026

About this page

Reviewer
Conphora compliance team
Reviewed
5 October 2026

General information, not legal advice. Check the legal text or ask an adviser about your own product.

Cite this page 
Conphora (2026). The authorised representative role in EU product compliance. Retrieved 13 October 2026 from https://www.conphora.com/roles/authorised-representative/
Reviewed

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