Looking to sell consumer goods in Europe? If your business is based outside this region, you'll need to appoint an Authorised Representative (AR).
Since Brexit and the introduction of tougher market surveillance and product safety rules, European AR requirements have become stricter. Customs officials, regulators and online marketplaces are now checking compliance more carefully than ever, making authorised representation essential for breaking into EU/UK markets.
This online guide walks you through everything you need to find an EU or UK Authorised Representative. We’ll cover what they do, when you need one, and how Hooley Brown can act as your Authorised Representative.
What is an Authorised Representative?
An Authorised Representative is your official presence in the EU or UK when you don't have your own company established there. It's a legal entity that acts on your behalf to fulfil specific compliance obligations and serves as your point of contact with market authorities.
Put simply, they're your regulatory stand-in in these markets. They represent your interests and ensure your products meet all safety and compliance standards.
What does an Authorised Representative actually do?
Your EU or UK Authorised Representative takes on specific legal responsibilities to ensure your products can be sold in EU/UK markets. They don't replace you as the manufacturer, but serve as your regulatory extension in these territories.
Their key responsibilities include:
- Managing your documentation
- Holding copies of your Declaration of Conformity/Performance
- Keeping your technical files accessible for at least 10 years
- Providing documentation to authorities when requested
- Dealing with regulatory authorities
- Being your official contact point for market surveillance
- Responding to official enquiries about your products
- Facilitating communication between you and authorities
- Ensuring proper product labelling
- Verifying that your products display the required contact information
- Making sure their details appear on products or packaging where required
- Handling compliance issues
- Alerting you to potential non-compliance situations
- Supporting corrective actions when problems arise
- Working with authorities during product investigations or recalls
The representative's exact responsibilities can be detailed in a written mandate that you provide, outlining precisely what they can do on your behalf.
When do you need an EU or UK Authorised Representative?
The rules around Authorised Representatives tightened significantly after Brexit and the introduction of Regulation (EU) 2019/1020 in 2021. This regulation closed previous compliance loopholes, particularly for e-commerce sellers and companies using fulfilment services.
You need an Authorised Representative when:
- Your business operates from outside the EU/UK
- Your products require CE or UKCA marking under relevant regulations
- You sell directly to EU/UK consumers without an EU/UK-based importer
- You use online marketplaces or fulfilment centres to reach EU/UK customers
Many businesses mistakenly believe they don't need an AR if they sell through platforms like Amazon. However, unless you have a formal arrangement with an EU/UK-based importer who explicitly accepts compliance responsibilities, you still need an Authorised Representative.
Which products legally require a UK or EU Authorised Representative?
Not all products need an AR. The legislation mainly applies to products that need CE marking under EU laws. Some of the key categories include:
- Construction products
- Electrical and electronic equipment
- Energy-related products
- Gas appliances
- Machinery
- Medical devices
- Personal protective equipment
- Toys
Similar rules apply to products that require a UK Conformity Assessed (UKCA) marking.
What's the difference between EU and UK Authorised Representatives?
Following Brexit, the UK established its own regulatory framework, leading to separate requirements for EU and UK markets.
EU Authorised Representatives
- Must be established in an EU member state
- Represent manufacturers for consumer goods sold in the EU market
- Deal with CE marking compliance
- Work with EU market surveillance authorities
UK Authorised Representatives
- Must be established in the UK
- Represent manufacturers for consumer goods sold in the UK market
- Deal with UKCA marking compliance
- Work with UK market surveillance authorities
If you're selling to both markets, you'll need representatives in both jurisdictions.
How does the EU GPSR regulation affect Authorised Representative requirements?
The General Product Safety Regulation (GPSR) came into effect in December 2024. It’s the most significant update to European safety laws in two decades.
Under GPSR, Authorised Representatives face enhanced accountability for the products they represent. They must verify that risk assessments have been conducted and that technical documentation is complete before products enter the market.
GPSR also extends to online marketplaces, which must now ensure sellers have properly appointed Authorised Representatives for regulated products.
For manufacturers and exporters, your Authorised Representative must understand expanded requirements and demonstrate compliance with GPSR's more rigorous standards when dealing with market surveillance authorities.
If you're already selling consumer products to EU markets, you should review your Authorised Representative arrangements to ensure they meet GPSR requirements for product safety and documentation.
Can you use a third-party as your EU Authorised Representative?
Most consumer goods manufacturers and sellers choose to work with a specialist compliance partner like Hooley Brown rather than establishing their own entity in the EU or UK.
Using a third-party as your Authorised Representative offers several advantages, including:
- Immediate compliance without the cost of setting up a European office
- Access to expertise in product-specific regulations
- Professional management of documentation and authority communications
- Reduced risk of compliance mistakes or oversights
How to choose the right EU or UK Authorised Representative for your business
Selecting the right Authorised Representative is a critical business decision that deserves careful consideration.
When you’re evaluating potential partners, look for a representative with experience handling your product category. Regulatory requirements can vary significantly across different industries.
If you’re selling to both EU and UK markets (as many businesses do), look for a compliance agency that can act as your Authorised Representative in both regions.
What are the risks of not having an Authorised Representative?
Failing to appoint an Authorised Representative can lead to serious problems when exporting to European markets. For example, customs officials could stop your shipments at the border, which could compromise sales.
In worst-case scenarios, your products may be seized or destroyed without compensation. That's inventory and revenue you'll never get back.
Market surveillance authorities can also force product recalls, which can damage both your finances and your brand's reputation. On top of all this, you could face hefty financial penalties for failing to meet AR requirements.
E-commerce platforms have also become stricter about compliance verification. Major marketplaces check Authorised Representative details during compliance reviews and will quickly remove non-compliant listings. They may even suspend your seller account.
Why choose Hooley Brown as your EU/UK Authorised Representative
At Hooley Brown, we specialise in removing regulatory barriers for businesses entering European markets. Our EU/UK representative services provide a straightforward solution to complex compliance demands.
We can also strengthen your European market position by providing:
- Safety assessment services across product categories
- Technical documentation support including maintaining safety test data, product files and certifications
- Instruction manual services including writing, illustration and localisation
- Multilingual labelling and packaging to meet local requirements
- Distribution network coordination with European partners
- Manufacturing compliance guidance and oversight
- Product notifications to relevant authorities when required
Our export strategy expertise means you can focus on selling your products rather than navigating the complexities of EU and UK compliance frameworks.
Don't compromise your European market access
Appointing an Authorised Representative isn't just a regulatory box to tick. It's essential for legally selling your products in the UK or EU. Without one, you face blocked shipments, marketplace restrictions and potential penalties.
Contact Hooley Brown for a straightforward assessment of your Authorised Representative needs and discover how we can keep your products flowing smoothly into European markets.
This guide provides general information on Authorised Representatives. For feedback specific to your business, please email hello@hooleybrown.com.
This article was published in May 2025. Regulations can change. Always verify current requirements and seek professional advice for specific situations.
