Authorised Representative Services EU and UK

Our Offer to You:

• Represent your products as your Authorised Representative (AR)
• Provide an EU or UK address to place on your products
• Use our extensive product compliance knowledge to efficiently check your technical documentation complies with product legislation
• Liaise with market surveillance authorities on your behalf

Why are Authorised representatives needed and when did it start?

1992 – General Product Safety Directive

Since the EU single market was launched, the General Product Safety Directive (GPSD) has regulated non-food, non-agricultural products. It requires economic operators such as ARs and importers to represent the safety of non-EU products to consumer protection and health and safety authorities (known as Market Surveillance Authorities). Only direct sales of non-EU products to end users have been exempt from EU representation.

1990s – CE marking

When CE marking system (called the New Approach) was rolled out to its various product sectors in the 1990s, many manufacturers and importers misunderstood that it supplemented rather than replacing the GPSD for those sectors. As a result, they often missed the requirement for representation as well as those for traceability and product recall.

2008 – NLF/RAMS

These shortcomings of the New Approach were identified and the New Legislative Framework 765/2008 (NLF) amended CE marking legislation to include the requirement for representation among other things. It is also known as the Regulation on Accreditation and Market Surveillance (RAMS.) It was launched in 2008, although it didn’t come into force in most sectors until 2016.

Jan 2021 – GB market separation

When the UK left the EU and the Great Britain and EU markets separated, GB and EU distributors of goods from the other side of the border became importers unless the manufacturer appointed an AR.

July 2021 – Market Surveillance Regulation EU 2019/1010 (MSR)

The Market Surveillance Regulation EU 2019/1010 (MSR) came into force in the EU tightening the rules for imported products to help consumer protection and health and safety authorities (known as Market Surveillance Authorities) trace and question overseas manufacturers about compliance.

MSR requires there to be an Authorised Representative or other Responsible Economic Operator based in the EU for all products placed on the EU market and covered by 18 of the 25 CE marking laws. They must liaise between the manufacturer and market surveillance authorities to deliver product compliance information and help with recalls and other product safety incidents.

The main effect was to extend the requirement for representation to non-EU goods sold online to EU end-users. Appointing an AR with expertise in product safety is the simplest way to get a responsible economic operator without disrupting the existing supply chain.

Market Surveillance Regulation was not implemented in Great Britain but RAMS still applies. Therefore non-GB, online products still do not need a GB economic operator, but if there is a GB distributor or retailer, they must represent products as the importer or Authorised Representative.

Authorised Representatives and other Responsible Economic Operators must:

• Check the manufacturer has
  • carried out the appropriate conformity assessment procedure;
  • technical documentation demonstrating compliance available;
  • applied the CE or other conformity marking (if applicable);
  • fulfilled their traceability obligations;
  • provided suitable instructions and safety information have been provided in the right languages.
• Provide an EU or GB name and address to mark on the product.
• Keep a copy of the declaration of conformity.
• Ensure technical documentation can be made available to the market surveillance authority upon request.

You can call us for further information about our UK Authorised Representative Services for selling products in the UK provided by authorisedrepcompliance.co.uk or if you require EU Authorised Representative Services for importing products into the EU then try authorisedrepcompliance.com

Do I Need an Authorised Representative?

The following flow chart from the EU Commission’s Guide explains who is the responsible economic operator depending on the supply chain:

Links:
EU guidance document: https://ec.europa.eu/docsroom/documents/46171Product Safety Portal: https://www.gov.uk/business-and-industry/product-safety
Market Surveillance Regulation (EU) 2019/1020: https://www.legislation.gov.uk/eur/2019/1020/contents
UK guidance document: https://www.gov.uk/government/publications/eu-regulation-20191020-on-market-surveillance-and-compliance-of-products

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