Do I Need an EU Economic Operator for CE-Marked Products Sold Online?

• Non-EU manufacturers selling CE-marked products online to the EU must appoint an EU economic operator (Regulation (EU) 2019/1020, Article 4).
• The General Product Safety Regulation (EU) 2023/988 extends this to all consumer products from December 2024.
• The EU Authorized Representative must be established in the EU and act as the official contact for authorities.
• Non-compliance can result in fines and removal of products from the EU market.
• Providers differ in price, scope, and included services—see the detailed comparison table below.

Updated 24 October 2026 · 9 sources checked

Providers compared

Prices as published on each provider's website on 24 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires: Article Numbers and Scope

EU law is clear and strict: if you are a manufacturer outside the EU and you place CE-marked products on the EU market—whether directly to consumers or via online platforms—you must appoint an economic operator established in the EU. This requirement is set out in Regulation (EU) 2019/1020, Article 4. The economic operator can be an importer, authorized representative, manufacturer with an EU presence, or a fulfillment service provider. For most non-EU online sellers, the only practical route is to appoint an authorized representative (AR).

From December 2024, the General Product Safety Regulation (EU) 2023/988 (GPSR) extends the requirement to all consumer products, not just CE-marked goods. This means almost all non-EU sellers of consumer goods (electronics, toys, household items, etc.) sold online to the EU must have an EU-based Responsible Person—a role that can be fulfilled by an authorized representative.

• Article 4, Regulation (EU) 2019/1020: Requires an economic operator for CE-marked goods.
• Article 16, GPSR (EU) 2023/988: Requires a Responsible Person for all consumer goods, effective December 2024.

The AR must be appointed by a written mandate, be named on the product, packaging, or accompanying documentation, and act as the official contact for EU authorities. The AR is responsible for holding technical documentation, cooperating with authorities, and facilitating corrective actions if needed. Importantly, the AR does not take over the manufacturer’s legal responsibility but ensures compliance procedures are followed. Non-compliance can result in fines, removal of products from the market, and blocked listings on platforms like Amazon and eBay.

How to Choose an EU Economic Operator or Authorized Representative

Choosing the right provider is essential for compliance and risk management. Start by confirming the provider is legally established in the EU and can sign a valid mandate. Next, compare what is included in their service: some only offer the legal minimum, while others provide additional support such as documentation storage, incident reporting, or regulatory updates. Always check for published pricing, clear renewal terms, and certificate verification methods (such as a QR code or public verification page).

Key factors to compare:

• Legal establishment: Must be in the EU; check registration details.
• Scope of mandate: Does it cover only Article 18 duties, or add extras?
• Certificate verification: Is there a public QR code or online check?
• Response times: How quickly will they forward authority or consumer requests?
• Exclusions: Are conformity assessment, testing, or incident management included?
• Renewal and switching: Is the renewal price stated up front? How easy is it to switch providers?

Below is a comparison of included and excluded services for each provider:

Always ask for a full list of exclusions and written confirmation of renewal prices before committing.

What the Price Really Includes (and Excludes)

Pricing for EU authorized representative services varies widely, and what is included for the published price can differ even more. For example, REP27’s €490/year covers a written Article 18 mandate, designation within 24 hours, a certificate with QR code, request desk, and documentation retention. It does not include conformity assessment, product testing, SBOM (software bill of materials) generation, or incident reporting—these are always external costs and must be arranged separately. Multi-mandate discounts are available if you combine GDPR, CRA, or GPSR services.

Other providers may include or charge extra for:

• Documentation storage for 10 years (Lappa, Cert-Rep)
• Incident reporting and complaints handling (Cert-Rep)
• Regulatory updates and compliance oversight (Lappa)
• Technical documentation checks (EaseCert, one-time fee)

Always check for renewal prices and whether the provider offers a clear, written renewal rate. Some providers offer a low first-year price but have much higher renewal fees or silent renewals. Switching providers can be complicated if documentation is not transferred smoothly or if there are notice periods.

Summary of what is included/excluded by provider (see table above for details):

• REP27: Transparent scope, clear exclusions, no upsells.
• Cert-Rep: Incident reporting and complaints handling included for higher price.
• Lappa: Ongoing compliance management, regulatory updates, and file storage.
• EaseCert: One-off compliance review, not ongoing representation.

Hidden Costs and Common Exclusions

Many providers do not publish all costs or exclusions up front. The most common hidden costs and exclusions include:

• Conformity assessment and testing: No authorized representative can perform these tasks; they must be done by notified bodies or security firms. These are often the most expensive parts of compliance, especially for higher-risk products.
• Incident reporting and complaints handling: Some providers include these, others charge extra or do not offer them at all. Cert-Rep includes these services for a higher annual fee.
• Renewal fees: Some providers do not state renewal prices up front, leading to unexpected increases after the first year. REP27 publishes renewal prices clearly.
• Per-request or per-incident fees: Rarely published; always ask if there are charges for handling authority requests or incidents.
• Liability limits: No representative assumes the manufacturer’s legal liability; the manufacturer always remains responsible for product compliance and safety.

Always request a written list of exclusions and confirm the renewal price before signing. For REP27, exclusions are clearly listed and not upsold later. For other providers, details may only be available on request.

How Appointment Works: Step-by-Step Guidance

Appointing an EU authorized representative is a legal and operational process. Here’s how it works in practice:

1. Confirm your obligation: Are you a non-EU manufacturer selling CE-marked or consumer products to the EU? If yes, proceed.
2. Choose a provider: Select a provider established in the EU. Check their legal entity registration and published scope.
3. Request written terms: Ask for a written mandate, renewal price, and a full list of included/excluded services.
4. Sign the mandate: The provider issues a written mandate (often with eIDAS electronic signature). You sign and return it.
5. Receive certificate: The provider issues a designation certificate (ideally with public verification, e.g., QR code).
6. Update documentation: Update your product labels, packaging, and technical documentation to name the representative.
7. Provide technical file: Send your technical file and declaration of conformity to the representative for retention.
8. Ongoing compliance: Ensure the representative is ready to answer authority requests and forward correspondence promptly.

Checklist for today:

1. Identify if your products are CE-marked or covered by GPSR.
2. Confirm your company is outside the EU.
3. Request written terms and renewal prices from at least two providers.
4. Ask for a list of included/excluded services and any extra fees.
5. Review your technical documentation for completeness.
6. Sign the mandate and update your product labeling and documentation.
7. Test the provider’s certificate verification (if available).

Decision Matrix: Do You Need an EU Economic Operator?

Use this decision matrix to determine your obligations based on company type, product, and sales channel:

For most non-EU companies selling physical goods to the EU, an authorized representative is mandatory. If you only sell to EU importers who take on all compliance duties, you may not need to appoint your own AR.

What Providers Usually Do Not Say

Many providers do not disclose key details up front, such as:

• Exclusions: Most do not list what is not included in the mandate. For example, conformity assessment, product testing, and SBOM generation are always external costs and never included in AR fees.
• Renewal prices: Some providers offer a low first-year price but do not publish renewal rates, leading to unexpected increases. REP27 is one of the few that publishes renewal prices clearly.
• Per-request or per-incident fees: Some providers may charge extra for handling authority requests, incident reporting, or complaints handling, but these fees are rarely published.
• Notice periods and switching: The process for switching providers, including notice periods and documentation transfer, is often not explained until after you sign.
• Liability limits: No AR takes over the manufacturer’s legal responsibility; the AR’s role is procedural, not substantive.

Always request a written list of exclusions, renewal terms, and switching procedures before committing. Ask for a sample certificate and test the verification process if available.

Realistic Scenarios: Which Obligation Applies?

• US SaaS company: No CE-marked products, but processes EU personal data. Needs a GDPR Article 27 representative, not an economic operator for products. REP27 and similar providers offer this service separately.
• Chinese Amazon seller: Sells CE-marked electronics to EU via Amazon. Needs an authorized representative for product compliance (Regulation (EU) 2019/1020, Article 4) and, from December 2024, a GPSR responsible person. REP27, Cert-Rep, and Lappa all offer suitable mandates. The seller must update product labels and provide technical documentation to the AR.
• UK online shop: Sells toys to EU consumers from the UK. Needs an EU authorized representative for CE and GPSR compliance, as the UK is now a third country. The shop must appoint an AR, update labeling, and ensure technical documentation is available in the EU.

In each scenario, the simplest compliant route is to appoint an EU-based authorized representative with a clear, written mandate and update all product documentation and labeling accordingly.