Authorized Representative EU

The full term "EU Authorized Representative" (European Authorized Representative) refers to a natural or legal person located within the European Economic Area (EEA, including the EU and EFTA) who is explicitly designated by a manufacturer outside the EEA. This person or entity is authorized to perform specific tasks required of the manufacturer under EU directives and laws.

According to the new EU product safety regulation "Market Surveillance Regulation (EU) 2019/1020," starting from July 16, 2021 (local time), most products bearing the CE marking must have an EU responsible person as the compliance contact within the EU (excluding the UK). E-commerce sellers in EU countries have also received notifications from Amazon, requiring sellers of products with CE markings to upload their EU authorized representative (EU Rep) information on time. Otherwise, products may fail customs clearance, product pages may be removed, or non-compliant products may even be delisted.

Why is an EU Authorized Representative Needed?

To ensure the safety of products sold in the EU market and to make sure that imported products bearing the CE marking comply with EU laws regarding consumer protection, property protection, and environmental protection, EU law mandates that manufacturers located outside the EU must appoint an Authorized Representative established within an EU or EFTA member country. This representative acts on behalf of the non-EU manufacturer in dealings with European governments and institutions.

What Are the Duties of an EU Authorized Representative?

1) Ensure that the product complies with all applicable EU regulatory requirements and maintain the Declaration of Conformity (DOC) and technical documentation.

2) Provide all relevant product information in a language understood by the competent authorities upon request.

3) Proactively report any potential product risks to the regulatory authorities.

4) Implement necessary corrective actions together with the authorities if products are found non-compliant.

Which Products Require an EU Authorized Representative?

Any product requiring a CE marking must have an EU Authorized Representative.

Currently, the majority of products sold in the EU market require CE marking. According to EU regulations, products such as electrical and electronic equipment, medical devices, general consumer goods, and construction materials must display EC REP (EU Authorized Representative) information on their packaging and instructions.

How to Apply for an EU Authorized Representative?

The representative must meet one of the following conditions:

1) The manufacturer is established within the EU.

2) The importer (if the manufacturer is not based in the EU).

3) An EU-based Authorized Representative (appointed in writing by the manufacturer to assume responsibilities and provide authorization documents to market surveillance authorities when requested).

4) A service provider for the product, such as an e-commerce platform.

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What Are the Consequences of Not Appointing an EU Authorized Representative?

1. Selling CE-marked products on Amazon Europe without an EU Rep is considered illegal. Amazon conducts regular checks, and non-compliance can lead to penalties against your products.

Recently, there have also been cases where sellers faced malicious complaints from competitors, resulting in product delistings, causing unnecessary trouble and loss. Therefore, eligible sellers should achieve compliance as early as possible.

2. If a product exported from outside the EU encounters issues during customs clearance, the EU Authorized Representative will assist in communicating with customs and resolving issues. Customs typically prefer dealing with the EU Rep rather than the exporter directly. Similarly, if problems arise during the product's sale within the EU, the EU Rep will assist in handling them. Thus, the EU Rep bears certain risks, and the higher the risk associated with the exporter's products, the greater the risk for the EU Rep.

3. EU customers often require exporters to provide EU Rep information to ensure product quality, uphold the exporter's reputation, and facilitate future communication.