EU Authorised Representative

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Harsh Vaidya

EU Authorised Representative for Non-EU Brands (GPSR 2024) | EuroSOR

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EU Compliance Series

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.

Dec’24
GPSR enforcement date, no grace period
20+
Product categories requiring an AR under EU regulations
1EU
Single AR required per product, not per country
€30k+
Typical maximum penalty per infringement under GPSR

Definition

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.

What “Authorised Representative” means legally
The AR acts under a written mandate from the manufacturer. They are named on the product as the EU contact, and market surveillance authorities serve notices and recall orders on the AR, not directly on the manufacturer.
ℹ
One AR covers the whole EU, not each country separately.

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.


What Changed in December 2024

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.

RegimeWhat triggered AR requirementCoverage
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 manufacturerAll consumer goods on EU market
Marketplace rules (Amazon, Zalando)Platforms enforce GPSR independently via seller account requirementsAll marketplace listings
⚠
Marketplaces are enforcing this ahead of authorities.

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.


Product Categories

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).

🔌
Electronics and Electrical
LVD + RED + GPSR
CE marking, voltage safety, radio equipment rules. AR required under LVD and RED directives, now also under GPSR.
🧸
Toys
Toys Safety Directive + GPSR
One of the longest-standing AR requirements. Physical appointment needed, not just a technical file.
🏋
Sports and Fitness Equipment
GPSR (new)
Previously unregulated for most products. GPSR created the AR requirement from December 2024.
🧴
Cosmetics and Personal Care
Cosmetics Regulation
Requires a Responsible Person in the EU, which functions identically to an AR. Long-standing requirement.
🏠
Furniture and Home Goods
GPSR (new)
No prior directive applied for most items. GPSR now makes a Responsible Person mandatory.
👶
Baby and Childcare Products
Toys Directive + GPSR
Highest enforcement scrutiny category. Market surveillance is active. AR documentation must be current.
🔧
Machinery
Machinery Directive
Technical file, Declaration of Conformity, and AR required. High penalty exposure for non-compliance.
👕
Clothing and Apparel
GPSR (new for most)
Most apparel had no prior AR requirement. GPSR changed this. Particularly relevant for Amazon EU sellers.
🔋
Batteries and Chargers
Battery Regulation + GPSR
New Battery Regulation adds AR-equivalent requirements on top of existing GPSR obligations.

Country-Level Requirements

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.

MarketEnforcement routeRisk levelWhat happens without an AR
🇩🇪 GermanyAbmahnung (cease-and-desist) from competitors; customs checks; Amazon DE enforcementHighCompetitor-initiated injunction before authorities even act. Legal costs significant.
🇫🇷 FranceDGCCRF market surveillance; customs at import; marketplace auditsHighProducts withdrawn from market. Fine of up to €30,000 per infringement under GPSR.
🇳🇱 NetherlandsNVWA inspections; port of Rotterdam customs; Amazon NL enforcementHighGoods seized at Rotterdam. Key import entry point for EU-bound stock.
🇪🇸 SpainAECOSAN surveillance; customs at Madrid and Barcelona; Zalando and Amazon ESMedium-HighProduct recall orders. Fast escalation if children’s products involved.
🇮🇹 ItalyMISE and local chambers; customs at Genoa and MilanMediumListing suppression on Italian marketplaces. Formal notice before penalty.
🇵🇱 PolandUOKiK market surveillance; rapidly improving enforcementMediumIncreasing enforcement activity since GPSR. High-growth e-commerce market with active monitoring.
🇸🇪 SwedenKonsumentverket; customs; Amazon SELowerLighter touch than Germany or France but legal requirement still applies. Marketplace enforcement active.

Appointment Process

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.

01
Scope
Define which products and regulations apply
An AR mandate is product-specific. Define which SKUs, applicable EU regulations (GPSR, LVD, RED, Toys Directive etc.), and the scope of responsibilities before drafting the mandate.
02
Contract
Written mandate signed by both parties
EU law requires a written mandate. It must specify: the manufacturer’s details, the AR’s EU address, which regulations are covered, and the AR’s specific obligations. A verbal arrangement has no legal standing.
03
Documentation
AR details added to product label or packaging
The AR’s name and EU address must appear on the product, its packaging, or in accompanying documentation before the product is placed on the EU market. This is what Amazon and customs authorities check.
04
Technical File
Transfer technical documentation to AR
The AR must have access to product declarations, test reports, and compliance documentation so they can produce these to authorities on request. This is an active, ongoing obligation, not a one-time setup.
05
Marketplace
Update marketplace listings
Amazon EU, Zalando, and similar platforms require GPSR Responsible Person details in the seller account. Add AR details to all relevant product listings to prevent suppression.
⚠
The AR cannot fulfill their role without the technical file.

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.


EuroSOR as Your EU Authorised Representative

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.

FAQ

Common Questions

Is an Authorised Representative the same as an EU Responsible Person under GPSR?
Functionally yes. GPSR uses the term “Responsible Person” while product-specific directives use “Authorised Representative.” Both refer to the same role: an EU-established entity whose details appear on the product and who holds accountability for compliance documentation. In practice, the same entity serves both functions.
Do I need an AR if I only sell on Amazon EU and not through my own website?
Yes. Amazon EU requires GPSR Responsible Person details on every product listing regardless of whether you have a separate DTC channel. The requirement is triggered by placing products on the EU market, not by the sales channel used.
Can my EU distributor be my Authorised Representative?
Technically yes, but it creates conflicts. A distributor acting as AR has commercial incentives that may not align with compliance obligations. If they terminate the distribution relationship, you lose your AR at the same time. Most compliance advisors recommend a dedicated AR appointment separate from your distribution arrangement.
What documents does my AR need to hold?
At minimum: the written mandate, Declaration of Conformity (for regulated products), technical documentation or test reports, and a record of the product’s compliance with applicable EU regulations. The AR must be able to produce these to market surveillance authorities within a reasonable timeframe on request.
Does an AR also handle EPR registration?
Not automatically. AR and EPR are separate obligations. An AR covers product safety compliance documentation. EPR registration covers producer responsibility for packaging, electronics, batteries, and similar waste streams. Some operators cover both, but they are distinct legal requirements with different registration processes.

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