What the regulations require.
A manufacturer that is not established in the EU must have a responsible economic operator based in the EU — and the name and address of that operator must appear on the product's labeling or packaging. The purpose is a broader effort to keep unsafe products off the EU market: it gives the market surveillance authorities a contact inside the EU to communicate with, and it makes investigation possible when something goes wrong.
Who can fill the role.
An authorized representative is not the only party that can act as the responsible economic operator — an importer established in the EU can also fill the role. (The regulation also recognizes an EU-established manufacturer and, in some cases, a fulfillment service provider.) Which option applies to you turns on a key distinction:
Importer
Places a product from a non-EU manufacturer on the EU market for the first time. Takes on far greater responsibility: verifying the manufacturer's compliance, ensuring their own name and address appear on the label or packaging, and holding the documentation the market surveillance authorities may request.
Distributor
Acquires the product from an importer or manufacturer within the EU for further distribution. Carries a duty of care, not an importer's obligations.
The full breakdown of the two roles — and the obligations that come with each — is in our guide, Importer or distributor?
The inflection point importers overlook
Place a product on the market under your own name or trademark, and you are no longer the importer — you have become the manufacturer, with a manufacturer's obligations. The same applies if you modify a product to a sufficient extent.
Why manufacturers choose an authorized representative.
For a manufacturer outside the EU, relying on importers to be your responsible economic operators has a structural weakness: whether an importer is the responsible operator depends on whether they supplied that particular product. An authorized representative designated by the manufacturer remains the representative for that product regardless of how the EU buyer acquired it. That independence — and blanket coverage across the whole EU — is why an authorized representative service is generally the cleaner arrangement.
If you sell through a dealership network, the case is clearer still: one designated representative keeps it unambiguous who represents you in the EU, and prevents your dealers from unknowingly becoming importers and failing in duties they never knew they carried. Most experienced EU-based importers prefer dealing with manufacturers that have an authorized representative in place. And with the representative appointed, you can also sell direct to EU consumers alongside your dealer network.
What we do as your appointed operator.
As an Authorized Representative service, we act as your appointed responsible economic operator: we provide our name, EU address, and contact details for your labeling and packaging, we hold the necessary documentation, and we engage with the market surveillance authorities in every jurisdiction where your product is sold.