Importer / Authorized Representative
Importer and Authorized Representative (AR) are two distinct roles defined under EU product legislation to ensure that non-EU products meet all regulatory requirements before entering the European market.
Importer
An importer is a natural or legal person established in the European Union who places a product from a third country on the EU market. Importers are legally responsible for ensuring that:
The product complies with applicable EU legislation.
A valid Declaration of Conformity (DoC) is available.
Technical documentation can be provided to national authorities upon request.
The CE marking and labeling are correct.
Their name and contact address are affixed to the product or packaging.
The act of placing on the market is performed by the importer for all products coming from outside the EU.
Authorized Representative (AR)
An Authorized Representative is a legal entity established in the EU who has received a written mandate from a manufacturer located outside the EU to act on their behalf. An AR may:
Keep the EU Declaration of Conformity and technical documentation available.
Cooperate with market surveillance authorities.
Fulfill specific tasks assigned in the mandate, but does not automatically assume importer responsibilities.
An Authorized Representative is not a substitute for an importer, unless also fulfilling that role.
Key Distinction
| Role | Details |
|---|---|
| Importer |
Legal Responsibility: Places product on EU market, assumes full compliance responsibility Trigger: Import of product Must Be EU-Based: Yes |
| Authorized Representative |
Legal Responsibility: Acts on behalf of non-EU manufacturer with limited mandate Trigger: Written authorization Must Be EU-Based: Yes |
| Role | Legal Responsibility | Trigger | Must Be EU-Based |
|---|---|---|---|
| Importer | Places product on EU market, assumes full compliance responsibility | Import of product | Yes |
| Authorized Representative | Acts on behalf of non-EU manufacturer with limited mandate | Written authorization | Yes |
Legal Basis
The roles of the Importer and the Authorized Representative (AR) are clearly defined under binding EU legislation. The following legal acts apply:
Regulation (EU) No 2019/1020 on market surveillance and product compliance
Regulation (EC) No 765/2008 setting out the requirements for accreditation and market surveillance
Sector-specific EU legislation, depending on the product type, including:
RED – Directive 2014/53/EU (Radio Equipment Directive)
EMCD – Directive 2014/30/EU (Electromagnetic Compatibility Directive)
LVD – Directive 2014/35/EU (Low Voltage Directive)
MDR – Regulation (EU) 2017/745 (Medical Devices Regulation)
Further details on the interpretation of these roles are provided in the European Commission’s official guide: Blue Guide on the implementation of EU product rules (2022 edition)
This guide explains key concepts such as placing on the market, CE marking, market surveillance, and the responsibilities of economic operators within the EU internal market.