What is an EU authorised representative?
GPSR Article 3(9) defines an authorised representative as any natural or legal person established within the Union who has received a written mandate from a manufacturer to act on that manufacturer's behalf in relation to specified tasks regarding the manufacturer's obligations under the Regulation. The mandate is the legal document that creates the role: without it, there is no valid authorised representative, whatever a label or a listing says.
GPSR Article 16(1) is the provision that actually requires this. It states that a covered product shall not be placed on the EU market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020. An authorised representative with a written mandate is one of four ways to satisfy that requirement; it is not a separate, optional extra.
EU authorised representative, EU Responsible Person, EU Rep, EC Rep: how the terms relate
Sellers hear several names for roughly the same idea, and they are not all identical. "EU Responsible Person" and "EU Rep" are market shorthand for the EU-established economic operator that GPSR Article 16 requires. "Authorised representative" is the precise legal term for one specific route to that role: the one created by a written mandate under Article 3(9). Where an EU importer or an EU-established manufacturer already covers the product, that operator is the Article 16 responsible person without any authorised-representative mandate at all.
"EC REP" is an older abbreviation, most familiar from CE-marked and medical-device labelling, for an authorised representative appointed under a different piece of EU harmonised legislation, not under GPSR. Depending on the product, a CE-sector authorised representative and a GPSR authorised representative can be two separate roles with separate mandates, even for the same company. Grüner Baum GmbH's service on this page is the GPSR Article 16 route: it does not extend to authorised-representative roles required under other, product-specific EU legislation unless separately agreed.
Quick reference: which term means what
| Term you hear | What it usually means | Legal basis to check |
|---|---|---|
| EU Responsible Person / EU Rep | Market wording for whichever operator satisfies GPSR Article 16 | GPSR Article 16 |
| EU authorised representative | The written-mandate route to that Article 16 role | GPSR Article 3(9) and Article 16(1) |
| EC REP | Authorised representative under CE-marking or medical-device legislation, a different framework | Sector-specific EU harmonised legislation, not GPSR |
| Importer | Can be the Article 16 operator instead of an authorised representative, if established in the EU | Regulation (EU) 2019/1020, Article 4 |
The four GPSR Article 16 routes
Article 16(1) requires an EU-established economic operator responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020. Reading that provision together with Article 4 of Regulation (EU) 2019/1020 gives four possible routes. An authorised representative with a written mandate is the route most non-EU manufacturers use when no EU importer already covers the product.
| Article 16 route | Who can be the responsible operator | Written mandate needed? | Typical case |
|---|---|---|---|
| EU-established manufacturer | The manufacturer itself, if established in the EU | No | Manufacturer already has an EU legal entity |
| Importer | An EU-established importer who places the product on the EU market | No separate authorised-representative mandate for this route | An EU distributor or import business buys and resells the product |
| Authorised representative | An EU-established person or company appointed in writing by the manufacturer | Yes, in writing, product-specific | Non-EU manufacturer sells directly, with no EU importer |
| Fulfilment service provider | An EU-established fulfilment provider, only where no manufacturer, importer or authorised representative established in the EU exists | Not an authorised-representative mandate, but the arrangement still needs evidencing | Stock sits in an EU fulfilment centre with no other EU operator in the chain |
What must the written mandate contain?
GPSR Article 10(2) sets the floor: the mandate must allow the authorised representative to, at minimum, provide a market surveillance authority with the information and documentation needed to demonstrate the product's safety on reasoned request, notify the manufacturer if it has reason to believe a product is dangerous, inform the competent national authorities of any corrective action through the Safety Business Gateway, and cooperate with those authorities on corrective action. In practice a usable mandate goes further and is explicit, written and tied to a defined product scope, not a general commercial understanding.
- Identity of the manufacturer and of the EU authorised representative
- The specific products or accepted product families covered, not an open-ended catalogue
- An explicit reference to GPSR Article 16 and the Article 4(3) tasks of Regulation (EU) 2019/1020
- The tasks the representative accepts under Article 10(2): authority information requests, notifying the manufacturer of a dangerous product, Safety Business Gateway notifications, and cooperation on corrective action
- The document flow: how technical documentation, risk assessments, labels and test evidence reach the representative and stay current
- Rules for using the representative's address on labels, packaging and online listings, limited to the accepted scope
- Start date, duration and how the arrangement ends
See the full mandate-contents checklist →
What does the authorised representative actually do?
Once a mandate is accepted, GPSR ties the authorised representative's work to Article 4(3) of Regulation (EU) 2019/1020 and, where the operator it appoints falls under Article 16(2), to periodic product checks.
- Keep the EU declaration of conformity or equivalent documentation, and the technical documentation, available for market surveillance authorities for the required period
- On a market surveillance authority's reasoned request, provide the information and documentation needed to demonstrate the product's safety, in a language the authority can understand
- Inform the market surveillance authorities if it has reason to believe the product presents a risk
- Cooperate with the authorities on action to eliminate or mitigate risks the product presents, including through the Safety Business Gateway
- Under Article 16(2), regularly check that the product's technical documentation, identification, manufacturer details and required warnings or safety information, including online-offer information, are in order
What the manufacturer still remains responsible for
Article 16 operates without prejudice to the duties of the manufacturer and other economic operators. Appointing an authorised representative moves specific Article 4(3) tasks to an EU-established operator; it does not transfer product safety itself.
The manufacturer keeps responsibility for designing and building a safe product, carrying out the internal risk analysis, keeping technical documentation accurate and current, and taking corrective action such as a recall when a product turns out to be dangerous. A written mandate defines what the representative accepted; it is not a certificate that the product is safe, and it does not substitute for the manufacturer's own compliance work.
Name and address on the product, packaging and online listing
Where the manufacturer is not established in the EU, GPSR Article 19 requires that a distance-sales offer clearly and visibly show the name, postal and electronic address of the responsible person within the meaning of Article 16(1), alongside the manufacturer's own name and contact details, information identifying the product, and any required warnings or safety information in a language consumers in the destination Member State can easily understand.
That address should only appear after the mandate has been accepted for the specific product, and only for the products the accepted mandate actually covers. Showing an authorised representative's address on a label, package or listing before acceptance, or for a product outside the accepted family, is not a valid Article 16 arrangement.
Who needs an EU authorised representative, and who doesn't
You typically need a written authorised-representative mandate when:
- Your manufacturing business is established outside the EU (for example in the United States, the United Kingdom after Brexit, China or Turkey) and sells directly to EU consumers
- You sell through your own online store, or through a marketplace such as Amazon, Etsy, eBay or a Shopify store, with no EU importer in the supply chain
- Goods ship to EU buyers from outside the EU, with no EU-established company placing the product on the EU market first
You do not need a separate authorised-representative mandate when:
- The manufacturer is itself established in the EU
- An EU-established importer already places the product on the EU market and is willing to take on the Article 16 role
- A fulfilment service provider already qualifies as the Article 16 operator under the narrow conditions where no manufacturer, importer or authorised representative established in the EU exists
Key terms on this page, defined
Each term links to its definition in the GPSR glossary, with the article it comes from.
Related reading
This page reflects the product-scope, documentation and Article 16 review practice of Germany-based Grüner Baum GmbH. Reviewed by Hatice Muazzez Bodur →
