FAQ

Questions, answered.

Everything manufacturers ask us about Authorized Representative services, responsible economic operators, and selling into the EU — answered plainly. Can't find yours? Ask us directly.

The basics

4 questions

What is a responsible economic operator?

A responsible economic operator is the person or company in the EU that market surveillance authorities can hold to account for a product. It can be an EU-based importer, an EU-based distributor, or an Authorized Representative appointed by the manufacturer. Whoever fills the role is responsible for engaging with the market surveillance authorities in the relevant jurisdictions.

What is the Market Surveillance Regulation?

'Market Surveillance Regulation' is the common name for Regulation (EU) 2019/1020 — the regulation that created the requirement for a responsible economic operator. Its purpose is to give market surveillance authorities a clear point of contact when they have a concern about the safety of a product, or need its technical documentation.

Why choose an Authorized Representative service?

It's a legal requirement to have the name and address of an EU-based responsible economic operator on your product. If you sell through an existing dealership network and change nothing, each dealer must take on the responsibility of an importer: placing their name and address on the product, holding your Declaration of Conformity on file, and providing technical files to the market surveillance authorities when requested. An Authorized Representative concentrates all of that with one partner instead.

Does the service cover the whole European Union?

Yes. Regardless of how you sell, we're identifiable through your labeling or packaging as your point of contact for market surveillance authorities across every jurisdiction in the EU.

Do I need one?

3 questions

I'm a non-EU manufacturer selling direct to consumers, and I hold all my own technical documents. Why do I need this?

Because holding the documents isn't the requirement — having an EU presence is. Under the two main regulations covering consumer products, a responsible economic operator based in the EU must be appointed, and their name and address must appear on the labeling or packaging. That's exactly what an Authorized Representative service provides.

Do I need this if I only sell to businesses, not consumers?

Generally no — if you sell solely to businesses and never to consumers, an Authorized Representative service isn't necessary. But the moment your product is available for purchase by a consumer, you must have a responsible economic operator in place — and that's what an Authorized Representative is for.

Once I appoint an Authorized Representative, can I sell direct to EU consumers?

Yes — and that's the clearest benefit. Without an Authorized Representative, a non-EU manufacturer selling direct has no responsible economic operator in place, which means you legally can't sell to consumers within the EU. With one appointed, you can.

Sounds like you need one?

Take the five-minute readiness check and see exactly where your documentation stands — free, no sign-up.

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Importers, distributors & rebranding

2 questions

I import products from a non-EU manufacturer. What are my obligations?

Understanding how your role is classified when you sell a product from an external manufacturer is vital. Depending on how you operate, you may be an importer or a distributor — with different obligations attached to each. Our guide Importer or distributor? walks through the distinction, and we can help you determine which you are — and help you fulfill those obligations.

I import and rebrand products under my own name. Am I still an importer?

No. If you sell a product under your own name or trademark, you stop being an importer and take on the responsibility of a manufacturer. That means compiling the relevant documentation and ensuring the product complies with EU regulation. Our CE compliance consultants can assist with compiling those documents.

The service

4 questions

Does the service include help completing missing documentation?

Generally, an Authorized Representative service doesn't extend to preparing documentation. But behind this service are the consultants of CE Equipment Solutions, who have been preparing CE documentation since 2015. If our vetting finds gaps, you'll know exactly what's missing — and our team can help you fix it.

How long does the service last?

One year, renewable for as long as you keep selling. At each annual renewal we ask for the number of units sold and the jurisdictions you sold into. An annual review of your technical documentation and its continuing compliance is also available on request.

Will one service cover all my products?

That depends on the agreement. A mandate for one product doesn't automatically cover your others — the products covered by the service are clearly listed in the mandate, so there's never any doubt about what's included.

What exactly is an Authorized Representative obliged to do?

An Authorized Representative must hold the technical documentation and Declaration of Conformity, pass any request from the authorities to the manufacturer in a timely fashion, and communicate with market surveillance authorities on the manufacturer's behalf. If an authority decides to withdraw or ban a product from the EU market, the Authorized Representative must communicate that to the manufacturer immediately.

Still have questions?

Ask us directly — or find out where you stand in five minutes.