European Authorized Representative (EUR)

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Ecommerce is a thriving industry and the internet makes it possible to sell
products all over the globe. 

However, when products are sold internationally, it’s not always easy to see
who the reseller is and where they are located. In the past, it has somewhat
been a free-for-all when it comes to selling products across the border to
consumers in the European Union. 

Often, manufacturers are located outside the European Union, such as in
China, the U.S. or the UK. When this happens, certain regulations must be
followed for the product to be sold within the EU.

 
If a product is sold directly to the end user without establishing a known
European economic operator, the EU has no control over the consumer
protection and there is a risk of unsafe products entering the market.

 
Regulation (EU) 2019/1020 was established to address this problem. It will be
effective from July 16th 2021 and it will require all sellers to have an
economic operator within the EU.

 
This Regulation states rules and procedures for economic operators regarding
products that are subject to certain Union harmonization legislation.

 
In other words, every business from outside the EU selling products directly or
indirectly (through ecommerce platforms) should have either an importer or an
authorized representative located in the EU, acting as a liaison between the
manufacturer based outside of the EU and a national authority within the EU.
The address of this economic operator must be clearly visible on the product
or packaging.

 
This regulation also means that Fulfilment Service Providers, such as
Amazon, are considered “economic operators”. This means that whenever
you sell a product on Amazon, Amazon will become for example responsible

for verifying and maintaining the technical file and declaration of conformity (if
they not take other measures and transfer this responsibility).

Even if your business is based outside of the EU and doesn’t sell solely
online, an Authorized Representative may be of added value. For example,
you may not want your importer to be the one who has access to your full
technical file, as it can often contain essential business knowledge.

 
And although an Authorized Representative has always been named in
previous European product safety regulation, such as the CE directives, as
someone who acts on behalf of the manufacturer in carrying out certain tasks,
with the (EU) 2019/1020, the AR will be in the spotlight again.

In this article, I’ll tell you everything you need to know about authorized
representatives, what they do and when you need one. I’ll give you practical
tips on how to determine whether you need an AR, and how to find yourself
one and make sure your product complies.

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