EU and UK Authorized Representative Services

Most products imported from outside the EU and EEA have needed an EU/EEA responsible person to represent their safety and compliance ever since the single market started in the 1990s. Distributors and importers can represent products they import but it is often not practical or desirable. For instance:

• The manufacturer may not wish to share technical compliance documentation, particularly if there are many importers or there is a confidentiality risk.
• Distributors may not want to or be able to take on the representation obligations.

Often, the simplest solution is for the manufacturer / exporter to appoint an AR like Authorised Rep Compliance.

CE and UKCA marking legislation lists obligations of distributors and importers. The extra obligations for a distributor who became an importers on 1^st January 2021 are:

• Ensure the appropriate conformity assessment procedure has been carried out by the manufacturer.
• Check the manufacturer has drawn up the appropriate technical documentation and affixed the relevant conformity marking (e.g. CE marking).
• Check the manufacturer has adequate traceability of products, customers and suppliers.
• Ensure their EU name and address is on or with the product;
• Keep a copy of declarations of conformity.
• Ensure technical documentation can be delivered to the market surveillance authorities on request.

You can relieve your EU and British distributors of these extra importer obligations by appointing us as your Authorised Representative.

General Product Safety legislation lists obligations of distributors and importers. The extra obligations for a distributor who became an importers on 1^st January 2021 are:

• Ensure that products meet the general safety requirement (safe according to the laws and standards of any EU member state, the state of the art and consumer expectations.)
• Check the manufacturer has drawn up technical documentation demonstrating compliance and it can be delivered to the market surveillance authorities on request.
• Check the manufacturer has adequate traceability of products, customers and suppliers.
• Ensure their EU name and address is on or with the product;

You can relieve your EU and British distributors of these extra importer obligations by appointing us as your Authorised Representative.

Market surveillance authorities such as consumer protection and health and safety authorities need to be able to make contact with the manufacturer and other people in the supply chain to deal with non-compliant products, particularly if they present a hazard to consumers. Having a person in their jurisdiction gives them greater powers to act.

No, it is mandatory to put the AR’s name and address on or with the product. They are permitted on the Declaration of Conformity and usually it is desirable but not mandatory.

If your EU distributors and retailers are prepared to take on the obligations of the producer then the answer is no. These obligations include checking the safety of the product, marking their name and address on it and dealing with consumer protection authorities. If they cannot take on these obligations or you do not want to use them as your importer then you must appoint an AR.

If your UK distributors and retailers are prepared to take on the obligations of the producer then the answer is no. These obligations include checking the safety of the product, marking their name and address on it and dealing with consumer protection authorities. If they cannot take on these obligations or you do not want to use them as your importer then you must appoint an AR.

CE marked products always need a responsible person when placed on the EU single market, even when a non-EU seller supplies an EU end user and there is no EU distributor. The first EU-based economic operator in the supply chain must represent the product unless there is an Authorised Rep.

UKCA and CE marked products only need a responsible person when placed on the GB market, when there is an importer, distributor or retailer. The first GB-based economic operator in the supply chain must represent the product unless there is an Authorised Rep. When a non-GB seller supplies an GB end user directly (e.g. online), an Authorised Rep or other responsible economic operator is currently not required but may be required in future.

General products only need a responsible person when placed on EU or GB market, when there is an importer, distributor or retailer. The first EU or GB-based economic operator in the supply chain must represent the product as the importer unless there is an Authorised Rep. An Authorised Rep or other responsible economic operator is currently not required for online and other direct sales from third countries.

We need to be sure that the product complies with the relevant product legislation. We ask for some of the technical documentation showing that it complies with:

• the general safety requirement of the General Product Safety legislation;
• the essential requirements of any CE or UKCA marking legislation;
• relevant standards, if applicable;
• any conformity assessment procedures requiring certification by a third party body;
• adequate user information
• declarations of conformity for CE/UKCA marked products
• adequate quality, traceability and product recall procedures

Our prices start from as little as £800 / €960 for contract set up and the first year’s representation for a small range of simple, low-risk products.

Our prices depend on four factors;

• Number of products/families of products,
• complexity of products,
• potential hazards and risk
• quality of supporting compliance information.

Here’s a recent example of how ARC resolved this for our client Sendmex:

1. Market Surveillance Alert
   The Danish Safety Technology Authority (DSTA) notified Sendmex that their CE-marked items on the EU market lacked any Authorised Representative information on the labels.
2. Swift AR Appointment
   Sendmex immediately appointed ARC to serve as their official EU Authorised Representative.
3. Formal Notification
   ARC sent a detailed letter to the DSTA, which:
   • Confirmed ARC’s appointment
   • Requested a short extension to assemble the necessary paperwork
4. Full Documentation Package
   Working closely with Sendmex, ARC:
   • Collected all relevant technical documentation
   • Drafted and executed the EU Declaration of Conformity
   • Advised on updating labels and online listings to display ARC’s details
5. Case Closure
   – The DSTA reviewed and accepted the documentation, closing the matter with no further action needed.

Key Point: If a surveillance authority flags missing AR details or compliance gaps, ARC will act quickly—liaising with the authority, securing extra time, and providing all the required conformity files to restore your full compliance.