EU and UK Authorised Representatives: Who Needs One, How Many, and How to Choose

No One Wants to Get in Trouble with a Foreigner

There is a rule that has held true throughout commercial history, in every market and every era: no one wants to get in trouble with a foreigner. Regulators and market surveillance authorities are no exception. When a product causes harm, or fails a compliance check, or triggers an investigation — the last thing an authority wants is to chase a manufacturer on the other side of the world with no legal foothold in their jurisdiction.

This is the practical reason behind the Authorised Representative requirement. It is not bureaucratic formality. It is a deliberate design choice by regulators who want someone local, accountable, and reachable — someone who speaks the same legal language and can be made to respond.

In the EU, that design choice has become law. And the scope of who needs a local representative is expanding, not shrinking.

The EU Authorised Representative: What It Is and When It Is Mandatory

For non-EU manufacturers placing products on the EU market under CE marking legislation, the obligation to appoint an EU Authorised Representative (EU AR) is set out in Article 4 of the Market Surveillance Regulation (EU) 2019/1020. The requirement is unambiguous: if no EU-based manufacturer or importer has formally assumed the economic operator role, a non-EU manufacturer must appoint an EU AR before placing the product on the market.

The EU AR must be a legal entity established in an EU member state.

Their role under the Market Surveillance Regulation includes:

• Verifying that the EU Declaration of Conformity and technical documentation have been drawn up correctly
• Holding a copy of the technical documentation and making it available to market surveillance authorities upon request
• Cooperating with authorities on any action taken in relation to the product
• Ensuring the manufacturer’s name and contact details appear on the product or its packaging

The EU AR is named in the Declaration of Conformity and their contact details must appear on the product label or accompanying documentation. They are not a passive mailbox. The 2025 Product Liability Directive reinforced this by explicitly stating that ARs are responsible for vetting compliance documents — they cannot simply rent out their name and address.

The full text of the Market Surveillance Regulation, which defines the AR’s legal role and tasks, is available on EUR-Lex.

The UK Situation: Clear for UKCA, Murkier for CE-Only Companies

Post-Brexit, Great Britain has its own equivalent: the UK Responsible Person (UKRP). Under the UKCA marking framework, non-UK manufacturers who place products on the Great Britain market through UKCA marking must appoint a UK-based Responsible Person. The UKRP’s role mirrors the EU AR in most respects — documentation, authority contact, labelling.

The ambiguity arises for manufacturers who do not use UKCA marking and instead rely on the UK government’s indefinite acceptance of CE marking in Great Britain.

If your product carries CE marking and you sell into Great Britain under that accepted route — without obtaining UKCA marking — do you still need a UK Responsible Person? The answer is not straightforwardly yes, but it is not safely no either.

The key variable is your distribution model. If an established UK importer places your products on the Great Britain market and formally assumes the importer role, they effectively act as the responsible economic operator in the UK chain. In that case, a separate UKRP appointment may not be strictly required.

However, if you sell directly into the UK — through your own e-commerce channel, through a marketplace where you are the seller of record, or without a UK entity formally assuming the importer role — the absence of a designated UK Responsible Person creates a legal gap that market surveillance authorities can act on. The CE marking acceptance policy does not suspend the requirement for a responsible economic operator to be present in the supply chain.

For manufacturers selling into both the EU and UK through direct channels, the practical answer is: appoint representatives in both markets. The commercial and legal risk of not doing so outweighs the cost of doing so.

Authorised Representative vs. Responsible Person: Not the Same Thing

One of the most persistent sources of confusion in this area is the assumption that all “representative” roles are equivalent. They are not. Three distinct legal figures exist, each defined under different legislation with different tasks:

The EU AR and the EU Responsible Person under GPSR overlap in some tasks but are legally distinct appointments under different regulations. A product subject to both CE marking legislation and GPSR may require both designations — or a single provider who formally accepts both mandates.

The GPSR has significantly expanded the universe of products requiring a local EU representative. Previously, the AR requirement primarily affected CE-marked products. Under the GPSR, virtually all consumer products sold in the EU by non-EU manufacturers require an EU-based Responsible Person — regardless of whether CE marking is involved. If your product does not require CE marking but is sold to consumers in the EU, you almost certainly need a GPSR Responsible Person. For more on the GPSR and which products it covers, see the General Product Safety Regulation page.

How Many Representatives Does Your Company Actually Need?

This is where most manufacturers are genuinely surprised.

Consider a manufacturer outside the EU producing a connected toy robot and exporting to the four largest European markets — Germany, France, Italy, and Spain — plus the UK. Here is the full picture of representative and responsible person appointments they may need:

• 1 EU Authorised Representative for CE marking (covering all EU member states)
• 1 UK Responsible Person for the UK market
• 5 national representatives for WEEE (Waste Electrical and Electronic Equipment) — one per country, as WEEE compliance is national
• 5 national representatives for Battery Regulation obligations — again, one per country
• 5 national representatives for Packaging and Packaging Waste obligations — one per country
• 1 EU Responsible Person under GPSR, if the robot is a connected or smart consumer device

That is 18 separate appointments for a single company selling into just five markets. If they also sell into the Netherlands, Belgium, or Poland, the number grows further.

Would having a subsidiary in one of those countries change things? Yes — but not dramatically. A German subsidiary would absorb some of the national mandates for Germany, but the rest of the chain remains. The complexity does not disappear; it shifts.

This is not an accident of regulation design. As EU rules become more specific and sector-focused, they are creating demand for specialised intermediaries who can respond to authority enquiries with genuine expertise — not just a forwarding address. The number of required representative appointments is growing, and the trend is not reversing.

Our free Crash Course on European Compliance covers this topic in one of its emails — including how to map the full landscape of representative obligations for your specific product and export markets.

How to Choose: Criteria That Matter

Not all EU AR services are equivalent. The range in quality, scope, and reliability is significant, and the consequences of choosing poorly surface at exactly the wrong moment — when an authority investigation is underway and your representative cannot locate your technical file.

Key criteria when selecting an EU AR or UK Responsible Person:

Regulatory competence for your product category. A representative who handles consumer electronics will not necessarily understand the conformity assessment requirements for machinery or medical devices. Sector-specific knowledge matters when authorities ask technical questions.

Genuine documentation management. The AR’s legal obligation is to hold and be able to produce your technical documentation. A provider who issues a certificate and files nothing is not meeting their legal obligations — and neither are you. Ask explicitly: where is the documentation stored, who manages it, and how quickly can it be produced?

Capacity to respond to authorities. Market surveillance actions can move quickly. Your AR needs to be reachable, responsive, and capable of engaging with authorities in the relevant language and jurisdiction. An offshore service that is unreachable during European business hours is a liability.

Clear contractual scope. The mandate agreement between manufacturer and AR should specify exactly what the AR is and is not responsible for. Vague agreements create disputes at the worst possible time. Read the contract carefully before signing.

Transparent pricing. Pricing in the market currently ranges from approximately €500–€1,500 per year for straightforward consumer products through SaaS-based services, to €1,500–€3,000 or more annually for complex regulated products, multiple SKUs, or services that include technical documentation review and ongoing regulatory support. Outliers at the very low end of this range warrant scrutiny — the obligations the AR is accepting are legal, not administrative.

What Cheap Can Actually Cost

A low-cost AR service that fails to maintain your documentation, fails to respond to an authority enquiry, or fails to notify you of a market surveillance action does not save you money. It concentrates risk.

When a product is ordered off the market, or an import shipment is seized, or a platform removes your listings because your AR cannot confirm compliance — the cost of that outcome is orders of magnitude higher than the annual fee you saved.

The Case for Centralising Your Representatives

Given the proliferation of representative appointments described above, the most operationally sensible approach is to consolidate as many mandates as possible with as few providers as possible.

A single provider who can serve as EU AR for CE marking, GPSR Responsible Person, and coordinator for national WEEE, Battery, and Packaging obligations across multiple member states offers a practical advantage that a collection of separate providers cannot: coherent documentation management, consistent authority communication, and a single point of contact for the manufacturer.

GetReady Compliance works with a specialised partner that offers CE + UK representative packages specifically designed for manufacturers entering both the EU and UK markets simultaneously — combining EU AR, GPSR Responsible Person, and UK Responsible Person services in a single, streamlined arrangement. These packages are structured to reduce the number of separate agreements a manufacturer needs to manage while maintaining full legal coverage in both markets.

If you would like to understand which representative appointments apply to your product and markets, and what a consolidated package would look like for your situation, request a quote.