Short answer
An EU Authorized Representative does not certify products and does not take over the manufacturer's responsibility for conformity. It acts under a written mandate: it keeps the Declaration of Conformity and technical documentation available to authorities, cooperates with them and reports risks. A responsible representative also reviews the documents before accepting the mandate, because its name appears on the product.
“We have an EU representative, so our product is CE certified.” We hear this often from manufacturers outside Europe. It is a misunderstanding that can cost a whole shipment.
Three common myths
Myth 1: the representative certifies the product
No. For most products, CE marking is a self-declaration by the manufacturer, based on testing and technical documentation. Where third-party assessment is required, it is done by a notified body, not by the representative. The manufacturer remains responsible for design, production and conformity.
Myth 2: a non-EU manufacturer cannot sign its own Declaration of Conformity
Also wrong. The EU Declaration of Conformity is signed by the manufacturer, wherever it is established. EU legislation allows the authorized representative to sign it only where the mandate gives it that task. Most of our clients sign their own Declaration; we review it first.
Myth 3: any EU address will do
A representative that never sees your documents cannot answer an authority’s request. If it cannot provide the technical file within the deadline, the consequences fall on your products and shipments.
What the representative must do
Under Article 4(3) of Regulation (EU) 2019/1020 and the specific product legislation, the representative must at least:
- keep the EU Declaration of Conformity and technical documentation available to market surveillance authorities, usually for 10 years;
- provide authorities with all information needed to demonstrate conformity;
- inform authorities when it believes a product presents a risk;
- cooperate on corrective actions.
What a responsible representative also checks
Some services only confirm that a technical file exists. Our policy is different: before we accept a mandate, ISOCONSULT S.R.L. reviews the content:
- the Declaration of Conformity: correct legislation, standards with dates, manufacturer as signatory;
- test reports: ISO/IEC 17025 accredited laboratory, current standards, the exact model sold;
- the risk assessment;
- instructions and warnings in the languages of the countries of sale;
- the label: CE marking, manufacturer, our details and traceability code.
We give you a gap report and approve the label in writing. Only then may our name appear on your product.
Warning signs when choosing a representative
- No questions about your products before signing.
- No written mandate defining the tasks.
- The price includes “CE certification” without testing or a notified body.
- No clear answer about how long documents are kept and how authorities’ requests are handled.
How ISOCONSULT works
See our five-step process and published prices, 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.