// GLOSSARY
Authorised Representative
An Authorised Representative is an EU-based legal entity or natural person appointed by a non-EU manufacturer to act on their behalf in relation to EU regulatory obligations. Under ESPR Article 16, non-EU manufacturers must appoint an Authorised Representative before placing products on the EU market.
Truth Anchor: This definition is based on Regulation (EU) 2024/1781 (ESPR) and related EU legislation. Source: EUR-Lex CELEX:32024R1781
Legal Obligations of the Authorised Representative
The Authorised Representative's obligations under ESPR are defined in Article 16. They must: ensure that the EU Declaration of Conformity and technical documentation have been drawn up and are available to market surveillance authorities; provide market surveillance authorities with all information and documentation necessary to demonstrate conformity; cooperate with market surveillance authorities on any action taken to eliminate non-compliance; and inform the manufacturer immediately of complaints and reports of accidents or safety issues.
Selecting an Authorised Representative
The Authorised Representative must be established in the EU and must have sufficient technical and legal expertise to fulfil their obligations. They must have access to the manufacturer's technical documentation and DPP data. The appointment must be documented in a written mandate. The Authorised Representative's name and address must appear in the EU Declaration of Conformity and on the product or its packaging.
Liability
The Authorised Representative is legally liable for ESPR compliance in the EU. If a product is found to be non-compliant, market surveillance authorities can take action against the Authorised Representative as well as the importer. Manufacturers should ensure that their Authorised Representative has adequate professional indemnity insurance and contractual protections.
Difference from Importer
The Authorised Representative is different from the importer. The importer is the person who places the product on the EU market (i.e., brings it into the EU). The Authorised Representative acts on behalf of the manufacturer in relation to regulatory obligations. A single entity can act as both Authorised Representative and importer, but the roles are legally distinct.
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EU Authorised Representative: When Is One Required?
An EU Authorised Representative is required when a manufacturer established outside the EU places products on the EU market. The requirement applies to manufacturers in all non-EU countries, including the UK (post-Brexit), the US, China, India, and all other countries. The AR must be established in the EU — a company incorporated in an EU member state. The AR acts as the manufacturer's legal representative in the EU for the purposes of EU product legislation, including ESPR. The AR's name and address must be included on the product, its packaging, or the accompanying documentation, and in the EU Declaration of Conformity.
Authorised Representative vs Importer vs Distributor
The EU Authorised Representative, the importer, and the distributor are three distinct roles under EU product legislation. The AR is appointed by the manufacturer and acts on the manufacturer's behalf for regulatory purposes. The importer is the company that physically imports the product into the EU and places it on the market — the importer has its own obligations under ESPR (verifying CE marking, keeping copies of the EU DoC). The distributor is a company further down the supply chain that makes the product available on the EU market without importing it directly. All three roles have distinct obligations under ESPR, and a single company may fulfil more than one role — for example, an exclusive EU distributor may also be the importer and the AR for a non-EU manufacturer.