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Why an EU Authorised Representative is Necessary if you are exporting to the EU

Post-Brexit, the UK is considered a "third country" by the EU. Therefore, UK businesses are not deemed to be established within the EU. Even if you possess an EU EORI number, this does not equate to having an establishment in the EU. The GPSR mandates that products placed on the EU market must have a responsible economic operator established in the EU or Northern Ireland.  This operator can be:​


  • The manufacturer (if based in the EU)

  • An importer (based in the EU)

  • An authorised representative (AR)

  • A fulfilment service provider​


If none of these entities are established in the EU, the product cannot legally be placed on the EU market .


Responsibilities of the Authorised Representative

An EU-based AR acts as the liaison between your business and EU market surveillance authorities. Their responsibilities include:​i


  • Maintaining and providing access to technical documentation

  • Cooperating with market surveillance authorities

  • Informing authorities of any risks associated with the product

  • Assisting in corrective actions when necessary​


It's important to note that while the AR facilitates compliance, the ultimate responsibility for product compliance remains with the manufacturer or importer.


Steps to Appoint an Authorised Representative

To comply with the GPSR and other relevant EU regulations:​


  1. Identify a Suitable AR: The AR must be a natural or legal person established in the EU or Northern Ireland.

  2. Establish a Written Mandate: This document should outline the tasks delegated to the AR and must be agreed upon by both parties.

  3. Provide Necessary Documentation: Supply the AR with all relevant technical documentation and information about the product.

  4. Update Product Labelling: Ensure that the AR's contact details are indicated on the product, its packaging, or accompanying documentation.


Failure to appoint an AR can result in products being denied entry into the EU market, potential fines, and reputational damage.


For further guidance, you may refer to the UK Government's detailed guidance on EU Regulation 2023/988 .​


Need help with the above?

Did you know the Chamber now offers Sustainability training and consultancy support. For more information click here or email us at international@gmchamber.co.uk

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