Authorised representative
A manufacturer can delegate certain tasks to an authorised representative in the EU. The core obligations stay with the manufacturer. The term should not be confused with the Assigned Representative on ENISA's reporting platform.
An authorised representative is a person established in the EU whom a manufacturer has appointed by written mandate to carry out specified tasks on its behalf. The role is optional and mainly intended for manufacturers outside the EU.
Definition in the Regulation
Article 3, point (15), of Regulation (EU) 2024/2847 defines the authorised representative as "a natural or legal person established within the Union who has received a written mandate from a manufacturer to act on its behalf in relation to specified tasks". Article 18(1) allows the manufacturer to appoint an authorised representative by written mandate. This is an option, not an obligation. Article 18(2) excludes the core obligations from the mandate: Article 13(1) to (11), drawing up the technical documentation (Article 13(12), first subparagraph) and conformity of series production (Article 13(14)) remain with the manufacturer. Article 18(3) sets out the minimum tasks: keeping the EU declaration of conformity and the technical documentation at the disposal of market surveillance authorities for at least ten years or for the support period, whichever is longer, providing evidence on reasoned request and cooperating on action to eliminate risks. A copy of the mandate must be provided on request.
What it means for manufacturers
A manufacturer based in the EU usually does not need an authorised representative. The role becomes relevant in groups of companies: if an EU subsidiary imports products of its parent from a third country, it is the importer. If it sells them under its own brand, it becomes the manufacturer itself under Article 21. A common solution is for the parent to remain the manufacturer and for the subsidiary to become both authorised representative, by written mandate, and importer; the documentation must then be available in the EU. The authorised representative under Article 18 is not the same as the Assigned Representative who submits notifications on ENISA's single reporting platform. Both can be the same person, but need not be.
Free templatesCRA Reporting KitReporting playbook, awareness record, notification templates for the ENISA platform, call chain and deadline calculator. Six Word templates, two Excel workbooks and a handbook, free by e-mail.Request the kit