EU Representative

EU Authorized Representative vs Importer vs Responsible Person: Who Does What?

Published: 12 November 2026 · ISOCONSULT S.R.L.

Short answer

Under Article 4 of Regulation (EU) 2019/1020, a product made outside the EU needs one economic operator established in the EU: an importer, an Authorized Representative with a written mandate, or, failing both, a fulfilment service provider. The importer buys and resells the goods; the Authorized Representative only acts on the manufacturer's behalf. Either can be the 'responsible person' named on the label.

If you manufacture in China, Turkey, India or anywhere else outside the European Union, sooner or later a customer, a customs broker or Amazon will ask you: “Who is your EU responsible person?” Three terms circulate, often mixed up: importer, Authorized Representative and responsible person. They are not the same thing.

The legal basis: Article 4 of Regulation (EU) 2019/1020

Since 16 July 2021, the Market Surveillance Regulation requires that certain products, including electrical equipment, electronics, radio equipment, toys, PPE and machinery, may only be placed on the EU market if there is an economic operator established in the Union responsible for specific compliance tasks. Article 4 lists who can take this role, in order:

  1. a manufacturer established in the EU;
  2. an importer, where the manufacturer is not established in the EU;
  3. an Authorized Representative with a written mandate from the manufacturer;
  4. a fulfilment service provider established in the EU, where none of the above exists.

The General Product Safety Regulation (EU) 2023/988 extended the same principle to consumer products in general from 13 December 2024.

“Responsible person” is not a fourth type of company. It is simply the common name for whichever of these operators takes the Article 4 role for your product.

Importer: the one who buys the goods

An importer is an EU company that places your product on the EU market in its own name. It typically buys the goods from you and resells them. The importer has its own legal obligations: it must check that you have carried out the conformity assessment, that the CE marking and documentation are in order, and it must put its own name and address on the product.

This works well when you sell through one large distributor per country. It works badly when:

Authorized Representative: the one who acts for you

An Authorized Representative does not buy or sell anything. It acts on your behalf under a written mandate that defines its tasks. Under Article 4(3) of Regulation 2019/1020, these tasks include at least:

Because the representative is independent of your sales channels, you can sell to any number of distributors, retailers or end customers in any EU country while one representative covers all of them.

Comparison

Importer Authorized Representative
Buys and resells the goods Yes No
Needs a written mandate No Yes
Name on the product Its own, as importer Its own, as EU representative
Keeps technical documentation Must be able to provide it Yes, under the mandate
Works with marketplaces and many distributors Difficult Yes

Which one do you need?

What to check before you sign

A serious representative will review your documents before accepting the mandate. If someone offers to “rent” you an EU address without looking at your test reports, that is a warning sign: in an inspection, a representative who never saw your file cannot defend it.

At ISOCONSULT S.R.L., we check the technical file, sign a bilingual mandate and approve your label before our name goes on your product. See how it works or request a quote.

This article is general information about EU product legislation and is not legal advice. Requirements depend on the exact product; contact us for an assessment of your case.

Selling into the EU from outside Europe?

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