EU Authorised Representative: Which Products Need One and How to Appoint
GPSR came into force in December 2024. Non-EU brands without an appointed Authorised Representative cannot legally place products on the EU market.
What an EU Authorised Representative Is
An Authorised Representative (AR) is an EU-established entity designated by a non-EU manufacturer to act as its legal point of contact for product compliance obligations inside the EU.
The AR does not distribute your products. They hold documentation, liaise with market surveillance authorities, and accept legal accountability for product safety compliance. Their details must appear on product labels, packaging, or accompanying documentation before goods enter the EU market.
Unlike VAT registrations or EPR obligations, a single AR appointment covers all 27 EU member states. You appoint one entity, and that entity’s details appear on the product documentation across the bloc.
GPSR Expanded the AR Requirement Significantly
Before GPSR (the General Product Safety Regulation), the AR requirement applied only to products covered by specific EU directives: toys, electronics, medical devices, and similar regulated categories. Most consumer products with no specific directive did not require an AR.
GPSR changed that. From 13 December 2024, any consumer product placed on the EU market by a non-EU brand requires a named Responsible Person with an EU address on the product or packaging. In practice, this is the AR function. The requirement now covers a large proportion of consumer goods that previously had no AR obligation.
| Regime | What triggered AR requirement | Coverage |
|---|---|---|
| Pre-GPSR (before Dec 2024) | Specific product directives only (LVD, RED, Toys, MDR, PPE) | Regulated categories only |
| GPSR (from Dec 2024) | Any consumer product from a non-EU manufacturer | All consumer goods on EU market |
| Marketplace rules (Amazon, Zalando) | Platforms enforce GPSR independently via seller account requirements | All marketplace listings |
Amazon EU began requiring GPSR Responsible Person details on product listings before the regulation’s enforcement date. Non-compliant listings are suppressed. This is often the first signal brands receive that they need an AR.
Products That Require an EU Authorised Representative
Two types of AR obligation exist: those driven by product-specific EU directives (existing) and those now triggered by GPSR for all consumer goods (new).
How AR Enforcement Varies Across Key EU Markets
The legal requirement is EU-wide. Enforcement intensity and the mechanisms that catch non-compliant brands vary by market.
| Market | Enforcement route | Risk level | What happens without an AR |
|---|---|---|---|
| 🇩🇪 Germany | Abmahnung (cease-and-desist) from competitors; customs checks; Amazon DE enforcement | High | Competitor-initiated injunction before authorities even act. Legal costs significant. |
| 🇫🇷 France | DGCCRF market surveillance; customs at import; marketplace audits | High | Products withdrawn from market. Fine of up to €30,000 per infringement under GPSR. |
| 🇳🇱 Netherlands | NVWA inspections; port of Rotterdam customs; Amazon NL enforcement | High | Goods seized at Rotterdam. Key import entry point for EU-bound stock. |
| 🇪🇸 Spain | AECOSAN surveillance; customs at Madrid and Barcelona; Zalando and Amazon ES | Medium-High | Product recall orders. Fast escalation if children’s products involved. |
| 🇮🇹 Italy | MISE and local chambers; customs at Genoa and Milan | Medium | Listing suppression on Italian marketplaces. Formal notice before penalty. |
| 🇵🇱 Poland | UOKiK market surveillance; rapidly improving enforcement | Medium | Increasing enforcement activity since GPSR. High-growth e-commerce market with active monitoring. |
| 🇸🇪 Sweden | Konsumentverket; customs; Amazon SE | Lower | Lighter touch than Germany or France but legal requirement still applies. Marketplace enforcement active. |
How AR Appointment Works in Practice
Appointing an AR is a contractual and documentary process. The mechanics are straightforward but the details matter, particularly the written mandate and how the AR’s details appear on product documentation.
Some brands appoint an AR but never send compliance documentation. If a market surveillance authority contacts the AR and the AR cannot produce the technical file, both parties are exposed. Keep the AR’s documentation current.
AR appointment included in the EuroSOR structure. Not a bolt-on. Not a separate contract.
EuroSOR (WareIQ Europe B.V., Netherlands) is EU-established and serves as your Authorised Representative and GPSR Responsible Person across all applicable product categories. The AR mandate sits within the same operating structure as IOR, VAT, and EPR compliance.
| Obligation | Standalone AR provider | With EuroSOR |
|---|---|---|
| AR / GPSR Responsible Person | Separate contract. Typically covers documentation only, no coordination with customs or marketplace. | Included within EuroSOR structure. EU address on product documentation. Same entity across VAT, IOR, EPR. |
| Marketplace compliance (Amazon, Zalando) | AR provider supplies details for you to update manually per listing. | Consistent entity details across all channels. IOR, VAT, and AR all match within one structure. |
| Market surveillance response | AR responds. May not have access to commercial context or logistics documentation. | Single point of accountability across compliance and operations. Faster resolution. |
| New product onboarding | New mandate required. Separate documentation update. Multiple parties to notify. | Add products within existing structure. No new provider engagement. |