EU Authorised Representative Services for Non-EU Manufacturers

• EU law requires non-EU manufacturers to appoint an authorised representative for many products and for data processing.
• REP27 and competitors offer mandates, certificates, public verification, and addresses for compliance.
• Providers vary: some charge per product, others per company or product category.
• Hidden costs may include document review, extra products, or per-request handling.
• Not all businesses need a representative—requirements depend on product type, sales channel, and market.

Updated 31 October 2026 · 16 sources checked

Providers compared

Prices as published on each provider's website on 31 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires: Article Numbers and Obligations

EU law imposes clear obligations on non-EU manufacturers and service providers to appoint an authorised representative (AR) established within the European Union. This requirement is not limited to a single regulation, but spans several key legal frameworks, each with its own scope and triggers:

• General Product Safety Regulation (EU) 2023/988: Articles 16 and 19 require that non-EU manufacturers of consumer products designate an EU-based economic operator (authorised representative, importer, or distributor) before products are placed on the EU market. If no AR is appointed, the legal responsibility falls to the importer or distributor. Websites selling to EU consumers must display the AR's details.
• Machinery Regulation (EU) 2023/1230: Article 12 mandates that non-EU manufacturers of machinery must appoint an AR via written mandate before products are placed on the EU market. This applies from 20 January 2027.
• Medical Devices Regulation (MDR 2017/745 and IVDR 2017/746): Article 11 requires non-EU manufacturers to designate a sole EU AR, whose details must appear on the device label. The AR is responsible for ensuring conformity assessment and notifying authorities of major incidents.
• GDPR Article 27: Any non-EU data controller or processor who processes personal data of individuals in the EU must appoint an EU representative, unless the processing is occasional, low risk, and does not include special categories of data.
• Other product-specific rules: Cosmetics (Regulation (EC) 1223/2009), AI Act, and environmental regulations (packaging, WEEE, batteries) also require an AR or responsible person established in the EU.

Failure to comply can result in fines, product withdrawal, or marketplace bans. The AR acts as the first point of contact for EU authorities and consumers, and must retain technical documentation and declarations of conformity for at least 10 years, as required by CE marking and product safety rules.

Key takeaway: If you are a non-EU manufacturer or service provider selling regulated products or processing EU personal data, you likely need to appoint an EU AR before entering the market.

How to Choose an EU Authorised Representative

Choosing the right EU authorised representative is crucial for compliance, smooth market access, and risk management. Here are the most important factors to consider, based strictly on published provider data:

• EU Establishment: The AR must be a legal entity established in the EU. Verify registration details and public records. For example, REP27's EU mandates are signed by Europe Services SE, a Societas Europaea registered in Prague since 2014.
• Scope of Service: Not all ARs cover every regulation or product type. REP27 covers GDPR, GPSR, machinery, cosmetics, AI Act, and more. Authoriseme.eu focuses on packaging, WEEE, and batteries. Cleo Labs and ProductIP offer broad product compliance, while EaseCert and Conformity Point are more focused on CE-marked products.
• Verification and Transparency: Publicly verifiable certificates and online validation are valuable for marketplace onboarding and regulatory checks. REP27 provides a certificate with QR code and public verification page; other providers may not offer this.
• Response Time: REP27 reviews and signs mandates within 24 working hours. Other providers may require more time, especially if technical documentation reviews are included.
• Included Features: Some providers include unlimited products (REP27 GPSR plans), while others charge per product or category (Cleo Labs, Conformity Point). ProductIP charges hourly for AR issues beyond the annual fee.

Always request a full list of included services, ask about hidden costs, and check if the provider's scope matches your products and markets.

What the Price Really Includes (and Hidden Costs)

Published prices for EU authorised representative services can be misleading if you do not read the fine print. Here’s how the main providers compare based on their public information:

• REP27: Charges per company for most services (e.g., from €190/year for GPSR, €290/year for GDPR, €690/year for cosmetics). The GPSR plans include unlimited products per company, one contract and invoice for EU & UK if needed, and public verification. Additional legal advice or technical file creation is not included.
• Cleo Labs: Starts from €1,500 per year per product category. Includes mandate, documentation retention, regular product checks, and expert monitoring. Details on extra fees are on request.
• EaseCert: One-time fee of €1,050 for onboarding, compliance review, and document checks. Ongoing AR support is not included and may incur extra costs.
• Conformity Point: Charges €199 per product for the first year, €119 for renewal. Covers mandate, basic technical file, and document retention. Ongoing support may be extra.
• ProductIP: High setup (€1,950) and annual fee (€2,150), plus €240/hour for handling AR issues. Best for complex portfolios needing ongoing support.
• Authoriseme.eu: Prices vary by country and product type (from €199/year for packaging, €150–870/year for WEEE & batteries). Fees depend on the specific compliance category and country.

Hidden costs to watch for:

• Per-product or per-category charges (Cleo Labs, Conformity Point, Authoriseme.eu)
• Hourly rates for incident handling (ProductIP)
• One-time onboarding or technical file review fees (EaseCert, ProductIP)
• Possible extra charges for urgent requests, document updates, or additional services (details often on request)

Always request a complete price breakdown and clarify what is included before signing.

How Appointment Works: Step-by-Step Process

The process of appointing an EU authorised representative is straightforward, but must be done carefully to ensure compliance and avoid delays. Here’s a step-by-step guide based on provider practices and legal requirements:

1. Identify your obligations: Determine which EU regulations apply to your products or services (e.g., GPSR, machinery, cosmetics, GDPR, AI Act).
2. Collect compliance documents: Gather technical files, declarations of conformity, and any supporting safety or data protection documentation.
3. Choose a provider: Compare published prices, included services, and scope. Verify that the provider is established in the EU and covers your product type.
4. Submit your file: Provide company and product details, compliance documents, and any required questionnaires. REP27 reviews files within 24 working hours; other providers may vary.
5. Provider review: The provider checks your file for completeness and may request clarifications or additional documents.
6. Mandate signature: Once approved, the provider signs the written mandate. REP27 issues a signed letter, certificate with QR code, and public verification code.
7. Update labels and documents: Add the AR’s name and address to your product labels, packaging, website, and privacy notices as required by law.
8. Verification: Authorities and marketplaces can check your AR’s status via public registers or verification tools (offered by REP27 and some others).
9. Ongoing compliance: Keep your documentation up to date, notify your AR of incidents, and respond promptly to authority requests.

Checklist for buyers:

1. Identify the relevant EU regulation(s) for your products/services.
2. Collect all technical and compliance documentation.
3. Shortlist providers based on scope and price.
4. Request a sample mandate and certificate.
5. Submit your application and documents.
6. Receive and implement the AR appointment.
7. Update all labels, packaging, and websites with the AR’s details.
8. Retain all compliance documents for at least 10 years.

Risks and Fines for Non-Compliance

Failing to appoint an EU authorised representative when required exposes non-EU manufacturers to significant legal and commercial risks. Here’s what can happen, based on official sources and regulations:

• Importer/distributor liability: If you do not appoint an AR, your EU importer or distributor becomes legally responsible for compliance, including safety, documentation, and incident reporting. This can deter business partners and limit your market access.
• Fines and penalties: Authorities may impose fines for non-compliance. The amount varies by regulation and member state, but can include substantial financial penalties, especially under GDPR or product safety rules.
• Product withdrawal: Non-compliant products can be withdrawn from the EU market, either by authorities or at the request of marketplaces such as Amazon or eBay.
• Marketplace bans: Major platforms require proof of an EU AR for many product categories. Failure to provide this can result in account suspension or product delisting.
• Reputational damage: Public enforcement actions and product recalls can harm your brand and customer trust.

Examples:

• GPSR: Non-EU sellers without an AR may see their listings removed from Amazon or other marketplaces.
• GDPR: Fines for non-EU controllers or processors without an Article 27 representative can reach significant amounts, depending on the data processing involved.
• Medical Devices: Failure to appoint an AR can result in product withdrawal and mandatory incident reporting to authorities.

Appointing a reputable AR with public verification and clear documentation is the simplest way to avoid these risks.

Decision Matrix: Do You Need an EU Authorised Representative?

Use this matrix to quickly check if your business needs an EU AR. When in doubt, consult the relevant regulation or ask the provider for a compliance check.

What Providers Usually Do Not Say

• Liability limits: Most ARs limit their liability to regulatory contact and documentation. They are not responsible for product defects or manufacturing errors.
• Notice periods: Changing or terminating your AR may require advance notice (details on request from each provider). Failing to update labels and documentation promptly can cause compliance gaps.
• Extra fees: Providers may charge for additional products, urgent requests, document updates, or handling authority incidents. ProductIP, for example, charges €240/hour for AR issues beyond the annual fee.
• Scope exclusions: Some ARs only cover specific regulations or product categories. Authoriseme.eu, for example, focuses on packaging, WEEE, and batteries, not general product safety or GDPR.
• Verification gaps: Not all providers offer public verification or certificates that marketplaces can check. This can slow down onboarding or lead to rejected listings.
• Legal advice: Most ARs do not provide legal advice or technical file creation as part of the standard fee. These services are often available only at extra cost or via partner law firms.

Always ask for a full contract, list of included services, and details on exclusions or extra fees before appointing an AR.

Realistic Scenarios: Which Obligation Applies?

• US SaaS company handling EU customer data: Must appoint a GDPR Article 27 representative. REP27 offers this from €290/year. The company must update its privacy notice with the AR’s details and retain documentation for authorities.
• Chinese Amazon seller shipping toys to EU consumers: Must appoint an EU AR for GPSR and possibly for CE-marked products. REP27 offers unlimited products from €190/year (GPSR). Cleo Labs and Conformity Point charge per product or category. The AR’s address must appear on the label and be provided to Amazon for listing approval.
• UK online shop selling cosmetics to EU: Must appoint a cosmetics responsible person under Regulation (EC) 1223/2009. REP27’s price starts at €690/year. The AR’s details must be on the packaging and in the product information file. Authoriseme.eu does not cover cosmetics, so a specialist provider is needed.

In each scenario, the simplest compliant route is to:

1. Identify the relevant regulation (GDPR, GPSR, cosmetics, etc.).
2. Collect required documentation (privacy notice, technical file, product information file).
3. Appoint an AR with public verification and clear scope.
4. Update all labels, websites, and documentation as required.

Failure to follow these steps can result in fines, product withdrawal, or marketplace bans.