What is an Authorised Representative?
An Authorised Representative (AR) is an EU- or UK-established party appointed by a written mandate from a non-established manufacturer to carry out defined compliance tasks on its behalf. For CE marked products, Article 4 of Regulation (EU) 2019/1020 (the Market Surveillance Regulation) requires an economic operator established in the EU — a manufacturer, importer, Authorised Representative or fulfilment service provider — before most CE-regulated products can be placed on the market. For manufacturers selling direct without an EU importer, appointing an AR is the standard way to satisfy the rule.
The UK mirrors the model for the GB market: UKCA-marked products from overseas manufacturers need a UK-established party carrying the equivalent obligations — commonly called the UK Responsible Person or UK Authorised Representative depending on the product legislation. Since Brexit, one representative can no longer cover both markets: an EU AR does not count for the UK, and vice versa. flexfrontier provides both under one agreement.
Since this date, Art. 4 of Reg. (EU) 2019/1020 bars CE-marked products from the EU market without an EU-established economic operator
CE marking spans the LVD, EMC, RED, Toys, Machinery, PPE, RoHS and more — the AR must know which apply to your product
How long the Declaration of Conformity and technical documentation must be kept at authorities' disposal
What the Authorised Representative actually does
- Holds the technical documentation and Declaration of Conformity at the disposal of market surveillance authorities, typically for 10 years after the last product is placed on the market.
- Appears on your product — the AR's name, registered trade name and address go on the product or its packaging and accompanying documents.
- Verifies the compliance dossier — checking that the DoC exists, cites the right legislation and standards, and matches the product actually shipped.
- Deals with market surveillance authorities — answering requests for information and documentation in the required language.
- Cooperates on corrective action — supporting risk elimination, withdrawals and recalls, and informing authorities where a product presents a risk.
- Registers products where required — sector databases and registrations that the legislation attaches to the AR role.
CE and UKCA markings, explained
CE marking is a legal declaration, not a quality stamp. By affixing it, the manufacturer declares — on its own legal responsibility — that the product meets every piece of EU harmonisation legislation that applies to it: the Low Voltage Directive for mains electronics, EMC for anything electrical, the Radio Equipment Directive for wireless products, the Toy Safety Directive, the PPE and Machinery frameworks, RoHS for hazardous substances, and more. No authority "issues" a CE mark: the manufacturer runs the conformity assessment, compiles the technical file, signs the Declaration of Conformity and applies the marking — involving a notified body only where the legislation demands third-party assessment (many toys, most PPE categories, some radio and machinery products).
UKCA is Great Britain's post-Brexit counterpart — same logic, UK legislation, UK-designated approved bodies. In practice the UK has announced indefinite recognition of CE marking for many product areas, including most consumer electronics, toys and machinery, so a compliant CE-marked product can generally continue to be sold in Great Britain. UKCA remains in use, certain sectors keep their own UK rules, and Northern Ireland follows EU rules under the Windsor Framework — so the right marking strategy depends on your product and channels, which we confirm during onboarding rather than leaving you to guess.
Where your Authorised Representative appears on the product
Several CE frameworks and Article 4 require the economic operator's name, registered trade name and postal address on the product — or, where size makes that impossible, on the packaging or an accompanying document. Your AR's details sit alongside your manufacturer details, next to the markings themselves. We supply the exact wording for your rating plates and artwork, and review labels before you print.
- On the product: manufacturer + AR name and address, model, batch or serial for traceability.
- Markings: CE (and UKCA where used) at minimum 5 mm, proportions intact — plus WEEE bin and other framework-specific symbols.
- In the paperwork: the AR named in the Declaration of Conformity and reachable in the language authorities require.
Which products need an AR?
The Article 4 requirement covers most of the high-volume CE legislation: the Low Voltage Directive, EMC, RoHS, the Radio Equipment Directive, the Toy Safety legislation, machinery, PPE, gas appliances, pressure equipment and construction products, among others. In practice, if your product carries a CE mark and you have no EU importer taking on the obligations, you need an EU AR. The UKCA regime imposes the parallel requirement for goods sold into the United Kingdom.
Sector regimes add their own versions of the role: medical devices require an EU Authorised Representative under the MDR/IVDR and a UK Responsible Person registered with the MHRA; cosmetics require a named Responsible Person under the EU and UK Cosmetics Regulations. flexfrontier covers these regulated categories as part of the same engagement.
AR vs GPSR Responsible Person vs importer — who does what?
These roles overlap on labels but sit under different laws, and many products need more than one:
A consumer electronics product sold direct from outside the EU typically needs an EU AR (for EMC/LVD/RoHS) and a GPSR Responsible Person — a role our AR mandate is drafted to absorb, so one appointment covers both. See our GPSR Responsible Person service.
Authorised Representative for Amazon, TikTok Shop and e-commerce brands
E-commerce is where AR gaps get found. Amazon retired its own Responsible Person programme, so sellers of CE-marked products — electronics, toys, PPE, radio equipment — must now provide their own EU economic operator details, on the listing and on the product. TikTok Shop and other platforms apply the same checks as they open EU marketplaces, and a listing without a valid EU operator is suppressed rather than fined. Selling on amazon.co.uk adds the UK layer: a separate UK-established representative for UKCA-scope goods.
We cover the full e-commerce stack under one agreement: EU AR and UK representation, labelling wording for products and packaging in the format platforms verify, compliance-document uploads during marketplace audits, and — because most consumer products also fall under the GPSR — the Responsible Person role folded into the same mandate. One appointment, every channel: Amazon EU and UK, TikTok Shop, your own store, and retail distribution.
How our AR service works
Because we share your liability, onboarding starts with a short compliance review of products and documents — most clients complete it within 24 hours.
Declarations filed in our name on your behalf through CDS and the EU national systems, with the correct representation codes — and CBAM authorisation where your goods need it.
Charges handled at the border and passed through at cost, itemised — with import VAT flowing to your own registration so recovery stays in your hands.
Every declaration archived audit-ready. If customs queries a declaration we signed, we stand behind it — that is what the shared liability means.
Authorised Representative pricing
AR services are priced as an annual fee per manufacturer, scaled by product range and risk category, with EU-only, UK-only and dual-market packages. Documentation review is included in onboarding, and there are no per-query charges when authorities contact us. Quotations are issued the same day.