Economic Operators · Authorised Representative
EU Authorised Representative: Mandate, Liability and Who Actually Qualifies
The authorised representative (also spelled "authorized representative") is a CE-marking-specific role, created by the harmonised directives — not GPSR, and not interchangeable with the GPSR Responsible Person or the importer, even though all three can be filled by a similar-looking EU-based service. Here is what the role legally requires, what the mandate document actually has to contain, and how far its liability really extends.
Authorised Representative at a Glance
- Who it is: an EU-established party the manufacturer formally appoints, in writing, for specific regulatory tasks
- Created by: the harmonised CE-marking directives, not GPSR
- Core document: a written mandate defining exactly what it is and is not authorised to do
- Liability: generally administrative and cooperative, not automatic joint liability for the underlying product
Quick answer: An EU authorised representative is an EU-established party a non-EU manufacturer formally appoints, in a written mandate, to carry out specific tasks under the CE-marking directives on its behalf — holding the technical file, acting as a contact point for authorities, and similar administrative/regulatory functions. It is a distinct role from the GPSR Responsible Person (a different regulation) and from the importer (which takes commercial title to the goods; the authorised representative never does). Liability is generally limited to the tasks the mandate actually assigns, not automatic responsibility for the product's underlying safety or conformity.
Legal Basis
A CE-Marking Role, Not a GPSR Role
The authorised representative comes from the harmonised CE-marking directives — the same legal family as the Declaration of Conformity and the CE mark itself — not from GPSR. This distinction gets lost constantly because GPSR's Responsible Person plays a structurally similar function (an EU-based contact and document-holder for a non-EU manufacturer) and the two roles are frequently bundled into one commercial service offering. Legally, they are separate appointments under separate regulations, and satisfying one does not automatically satisfy the other, even when the same EU-based company ends up holding both roles for the same product.
Not every CE-relevant directive requires an authorised representative — some allow the manufacturer to handle everything directly if it is itself EU-established, and appoint an authorised representative only when the manufacturer is outside the EU and the specific directive calls for one, or when the manufacturer chooses to delegate specific tasks voluntarily.
The Mandate
What a Real Authorised Representative Mandate Actually Contains
"Written mandate" is not a formality — it is the document that defines the entire scope of what the representative can and cannot do. Here is what a genuine one contains.
Scope: product or product group
The mandate covers a specific product or defined product group, not a vague "all our products" blanket statement — a new product line generally needs its own mandate coverage confirmed, not assumed.
Explicit task assignment
A specific list of tasks delegated — commonly holding the technical documentation, acting as contact point for market surveillance authorities, and cooperating with corrective-action requests — stated individually, not as an open-ended catch-all.
Effective date and duration
When the mandate takes effect and how long it runs, since an authorised representative acting outside an active, dated mandate has no genuine authority for that product.
What cannot be delegated
Product design, the manufacturer's quality-management responsibilities, and authorship of the technical file's underlying content remain the manufacturer's exclusive responsibility — a mandate cannot legally transfer these, only the administrative tasks around them.
Confidentiality terms
Given the representative holds sensitive technical documentation on the manufacturer's behalf, a genuine mandate includes confidentiality obligations, not just a task list.
Signature and acceptance
Signed acceptance by both the manufacturer and the representative — an unsigned draft or a one-line email is not a mandate a regulator will treat as valid.
Liability
How Far Authorised Representative Liability Actually Extends
This is the most commonly overstated part of the role — both by services that want to sound reassuringly comprehensive, and by manufacturers who assume appointing a representative transfers away their own responsibility.
What the representative is generally liable for
Failing to perform the specific tasks the mandate actually assigns — for example, being unreachable when an authority requests the technical file it is supposed to hold, or failing to cooperate with a legitimate corrective-action request.
What generally stays with the manufacturer
The underlying product's safety, design and conformity remain the manufacturer's responsibility. Appointing an authorised representative does not transfer product liability for a genuine design or manufacturing defect — the representative's exposure is tied to its own administrative role, not automatically to the product itself.
Exact liability allocation can vary by the specific directive and jurisdiction involved, and high-liability product categories may carry different rules — this page describes the general pattern, not a substitute for legal advice on a specific high-stakes product.
Authorised Representative vs Importer
The Difference Is Commercial Title, Not Just Paperwork
| Authorised Representative | Importer | |
|---|---|---|
| Takes commercial ownership of the goods? | No — never buys or resells the product | Yes — places the product on the market commercially |
| Created by | A written mandate from the manufacturer | The act of commercially placing the product on the EU market |
| Core function | Administrative/regulatory contact point for specific delegated tasks | Verification that the manufacturer's obligations were met, before market placement |
| Can be the same party? | Yes, if separately and explicitly appointed for each role | |
A worked example: a logistics company that buys your product wholesale and resells it into the EU is functioning as your importer — it holds and sells the goods. A separate compliance-services company holding your technical file and liaising with regulators, without ever buying or reselling anything, is functioning as your authorised representative. Confusing the two, or assuming one automatically covers the other, is a common and avoidable gap.
Who Needs One
When an Authorised Representative Is Actually Required
Genuinely required
A non-EU manufacturer whose product falls under a directive that specifically mandates an authorised representative, or requires one as a condition of using certain conformity-assessment routes — the exact trigger depends on the specific directive, not a universal CE-marking rule.
Often chosen voluntarily
A non-EU manufacturer with no EU establishment at all frequently appoints one anyway, even where not strictly mandated, simply to have a reliable EU-based point of contact for market surveillance and notified-body communication — a practical choice, not always a legal requirement.
An EU-established manufacturer handling its own CE-marking obligations directly generally has no need to appoint one at all — the role exists specifically to bridge the gap for manufacturers outside the EU, or to formally delegate specific tasks a manufacturer chooses not to handle itself.
Appointment & Termination
How a Mandate Starts and Ends
Appointment
The manufacturer and the prospective representative sign the written mandate, scoped to specific products and tasks. The representative's details then need to appear correctly wherever the manufacturer's own details are required — technical documentation, and product labelling where the directive calls for it.
Termination and replacement
Ending a mandate is not simply walking away — in most frameworks a successor representative should be named and accepted before the outgoing one's mandate lapses, so the product is never left without a valid representative. Authorities and, where relevant, notified bodies typically need to be informed of the change.
A Pattern We See Often
"We Assumed Our Responsible Person Was Also Our Authorised Representative"
A manufacturer appoints a GPSR Responsible Person to cover general product safety, and later learns their electronics product also needs CE marking with a properly appointed authorised representative. They assume the existing Responsible Person relationship already covers it, since it is the "same kind of EU compliance contact" service. It does not — the Responsible Person appointment is a GPSR document; it says nothing about CE-marking tasks, and no authorised representative mandate exists until one is separately signed. The gap only surfaces when a notified body or market surveillance authority asks specifically for the authorised representative's mandate and technical-file access, and no valid one can be produced.
The fix: treat each economic-operator appointment as its own explicit, written, product-scoped document — never assume one role's paperwork silently covers another, even when the same company holds both.
Cost
What an Authorised Representative Service Typically Costs
As with the Responsible Person role, published "authorised representative cost" figures vary widely across providers and change over time — we would rather explain what drives the cost than quote a number that may already be stale by the time you read it.
Product risk class
Higher-risk categories requiring more extensive technical-file oversight and more frequent authority interaction generally command a higher recurring fee than low-risk, self-declared categories.
Number of product lines covered
Most services price per product or product family covered under the mandate, not a single flat organisational fee — the cost scales with your actual catalogue, not your company size alone.
Bundled vs standalone service
Some providers bundle the authorised representative role with the GPSR Responsible Person role at a combined rate; others price them separately — worth clarifying which you are actually being quoted before comparing providers.
Also Setting Up VAT in the EU? That's a Different Representative Role
An authorised representative (covered on this page) is a product-conformity role under the CE-marking directives — it has nothing to do with tax. If you also need to register for VAT as a non-EU business, that requires a separate fiscal representative, governed entirely by VAT law, not product law. Our sister site Bulgarian.LLC covers this in depth: Fiscal Representative in Bulgaria: Who Needs One, and Who Does Not — useful if EU VAT registration is part of your market-entry plan alongside product compliance.
Incorporating in Bulgaria Specifically? There's a Third "Authorized Representative"
If your EU market-entry plan includes setting up a company in Bulgaria, you may also come across "authorized representative" in a third, entirely different sense: a power-of-attorney holder who signs company-registration documents, opens the bank account or files with the Commercial Register on your behalf when you cannot be physically present. That is a Bulgarian company-law concept, unrelated to both the CE-marking role on this page and the VAT-law fiscal representative above. Bulgarian.LLC's guide covers it directly: Authorized Representative Bulgaria: Power of Attorney, Process, Cost.
FAQ
Common Questions About the Authorised Representative Role
Is an authorised representative the same as a GPSR Responsible Person?
No — they come from different regulations (CE-marking directives vs GPSR) and require separate written appointments, even though the same EU-based company can hold both roles for the same product if formally appointed for each.
Who can be an authorised representative?
Any EU-established natural or legal person the manufacturer chooses to appoint in writing — there is no separate licensing or certification required to become one, though the appointing manufacturer should confirm the representative genuinely has the capability to perform the tasks being delegated.
Can an authorised representative refuse to hand over the technical file to an authority?
No — providing the technical documentation to a market surveillance authority on legitimate request is typically one of the core tasks the mandate assigns, and failing to do so is a failure of the representative's own obligation, independent of any dispute it might have with the manufacturer.
Does every CE-marked product need an authorised representative?
No — an EU-established manufacturer handling its own CE-marking obligations directly generally does not need one. The role becomes relevant specifically for non-EU manufacturers under directives that require or permit the appointment, or where a manufacturer chooses to delegate specific tasks voluntarily.
What happens if my authorised representative goes out of business?
The mandate lapses, and the product is left without a valid representative until a new one is appointed — treat this as an active risk to monitor, not a one-time appointment you never revisit, particularly for a smaller or newer service provider.
Is "authorized representative" (US spelling) a different role from "authorised representative"?
No — it is the same EU regulatory role; the spelling difference is purely regional English usage (authorised vs authorized), not a legal distinction.
Can I have more than one authorised representative at the same time?
Generally no for the same product under the same directive — having two active, potentially conflicting mandates for identical tasks on the same product creates exactly the ambiguity the role is meant to eliminate. Different products, or genuinely different delegated tasks, can be split across different representatives if you have a specific reason to.
Does the authorised representative need to be based in the specific EU country I sell most into?
No — EU establishment anywhere in the Union generally satisfies the requirement, since the harmonised directives apply uniformly across all 27 member states. Being based in your highest-volume market can be a practical convenience, but it is not a legal requirement.
Related Guides
Where to Go Next
All Economic Operator Roles
The full picture — manufacturer, importer, distributor, Responsible Person and Only Representative compared.
EU Importer
The role that does take commercial title to the goods — often confused with the authorised representative.
CE Marking
The framework that created the authorised representative role in the first place.
Where the Facts Come From
Sources for This Page
The authorised representative role is defined across the harmonised CE-marking directives referenced on our CE Marking page (Tier 1, EUR-Lex). The European Commission's Blue Guide (Tier 1–2) is the primary source for mandate mechanics and how the role interacts with the manufacturer and importer. Liability-scope description on this page is general pattern guidance (Tier 3), not a substitute for legal advice on a specific high-liability product category.
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