We want to appoint an authorised representative

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 all information and documentation necessary to demonstrate the safety of the product, in an official language the authority understands; 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 sector acts have their own article. 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 shall not form part of the mandate (Article 7(1)). The Commission's Blue Guide describes the delegable tasks as administrative, requires the delegation to be explicit and in writing, and notes that the representative cannot modify the product on its own initiative (section 3.2).^[3][4]

A second, separate role is the responsible economic operator. For products under the acts listed in Article 4(5) of Regulation (EU) 2019/1020, and for products covered by the GPSR, a product may be placed on the market only if an operator established in the Union is responsible for the tasks in Article 4(3): verifying that the declaration and technical documentation have been drawn up, keeping the declaration available, providing information to authorities, informing them of risks and cooperating on corrective action (Article 4(1) and (3); 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)). Under the GPSR, the responsible operator also regularly checks the product against its technical documentation and its marking, where appropriate with regard to the risks (Article 16(2)).^[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 from its responsibilities to an authorised representative (section 3.1). For products placed on the market or put into service from 9 December 2026 the role also carries civil liability: the authorised representative of a manufacturer outside the Union is among the operators liable under the Product Liability Directive (EU) 2024/2853 (Articles 2(1) and 8(1)(c)).^[2][4][5]