EU Authorised Representative for CE-Marked Products: Cost & Comparison (2026)

• REP27 — Europe Services, SE: €490/year, €440 renewal (price_verified_on_source_page)
• Covers Article 18 mandate; excludes conformity assessment/testing
• Competitors rarely publish prices; most are 'On request'
• Mandate is required for non-EU manufacturers under EU law
• Manufacturer retains liability for product compliance

Updated 22 October 2026 · 7 sources checked

Providers compared

Prices as published on each provider's website on 22 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires: Article Numbers and Obligations

For non-EU manufacturers, appointing an EU authorised representative is a legal requirement before placing CE-marked products on the EU market. The obligation is set out in several key pieces of EU legislation:

• Regulation (EU) 2019/1020: This regulation requires non-EU manufacturers to designate an EU-based economic operator—such as an authorised representative—before their CE-marked goods can be sold in the EU. The representative must be established in the EU and act on the manufacturer’s behalf for procedural and contact functions (source).
• Article 11 of Regulation (EU) 2017/745: This article specifically mandates that non-EU manufacturers of medical devices must appoint an EU Authorised Representative before placing their products on the EU market (source).
• Other sector-specific regulations may also require an authorised representative, depending on the product category.

The representative’s role is to handle compliance documentation, respond to requests from EU authorities, and act as a point of contact. However, the manufacturer remains responsible for product design, manufacture, and conformity assessment. The representative does not assume legal liability for the product’s compliance (source).

Failure to appoint an authorised representative can result in products being denied entry to the EU market and exposure to regulatory penalties. Appointing a representative is not optional for non-EU manufacturers of CE-marked products; it is a mandatory step in the compliance process.

How to Choose an EU Authorised Representative

Choosing the right EU authorised representative is critical for compliance, operational efficiency, and risk management. Here’s how to approach the selection process:

• Check price transparency: Many providers do not publish their prices or renewal terms. REP27 — Europe Services, SE is one of the few that does, listing €490/year and €440 for renewal. Always request written confirmation of all fees and renewal conditions.
• Verify legal establishment: The provider must be legally established in the EU. For example, REP27 is based in the Czech Republic and registered since 2014. Some competitors are based in the UK, which is no longer part of the EU; ensure the actual representative is EU-based if your product requires it.
• Assess scope of service: A proper mandate should be limited to procedural duties (such as those under Article 18) and not claim to cover manufacturer responsibilities, which remain with you. Be wary of providers who offer to take on duties forbidden by law.
• Certificate verification: Ask how the provider’s certificate can be verified by authorities. REP27 offers a QR code and public verification page. This is crucial for smooth customs and regulatory checks.
• Request desk and language support: Confirm how requests from authorities or data subjects are handled, in which languages, and within what timeframe. REP27 forwards requests within two business days.
• Clarify exclusions and extra fees: Demand a list of what is not included (e.g., conformity assessment, testing, SBOM generation). REP27 explicitly lists exclusions; most competitors do not publish this information.

Always request written confirmation of what is included and excluded before making a decision. Providers that cannot list exclusions may not have a clear understanding of their own service scope, which can lead to compliance gaps.

What the Price Really Includes

The published price for an EU authorised representative can vary significantly, and most providers do not disclose their fees publicly. REP27 — Europe Services, SE stands out by publishing a clear price: €490 for the first year and €440 for renewal, with lower rates available in bundles (e.g., combined with GDPR or NIS2 representation).

• Included with REP27:
• Written Article 18 mandate for CE-marked products
• Signed certificate with QR code and public verification page
• Request desk for forwarding authority and data subject requests within two business days
• Multi-regulation options: add GDPR Article 27 or NIS2 representation on a single invoice
• Clear renewal pricing stated upfront
• Not included:
• Conformity assessment (must be done by a notified body, especially for important class II and critical products)
• Product testing (handled by security or testing firms)
• SBOM (Software Bill of Materials) generation (your responsibility)
• Incident reporting (your security team’s duty)
• Competitors: Global CE Marking, Lappa, and Comply Express do not publish their prices or detailed inclusions/exclusions. You must request this information directly.

Always check for hidden costs such as per-request fees, silent renewals, or charges for certificate verification. REP27 explicitly states there are no upsells for excluded services, and the renewal price is disclosed before you pay the first invoice.

For most standard products, the external spend for the representative mandate is small compared to the internal engineering and documentation costs of compliance. However, for important class II or critical products, notified body assessment is mandatory and can cost thousands, far exceeding the representative’s fee.

Hidden Costs and Exclusions

Understanding what is not included in your representative’s mandate is just as important as knowing what is. Many providers do not publish their exclusions, which can lead to unexpected costs and compliance failures. REP27 — Europe Services, SE is explicit about what is excluded:

• Conformity assessment: Only a notified body can perform this for important class II and critical products. The representative’s role is strictly procedural.
• Product testing: This must be contracted separately with a certified testing or security firm.
• SBOM generation: This is part of your internal build process and not included in the representative’s service.
• Incident reporting: Your security team is responsible for reporting and handling incidents; the representative does not manage these processes.

Other hidden costs to watch for in the market:

• Silent renewals: Many providers offer a low first-year price but do not disclose the renewal cost until after you are committed. Always demand the renewal price in writing before signing.
• Per-request or per-incident fees: Some providers charge extra for handling requests from authorities or data subjects. REP27 does not state any such fees.
• Notice periods: Check the contract for minimum notice periods for termination or switching providers. This is often omitted from public information.
• Liability limits: The manufacturer always retains legal responsibility for product compliance; the representative’s liability is strictly limited to their procedural duties.

Before appointing any provider, ask for a comprehensive list of exclusions and extra fees. If a provider cannot provide this, consider it a red flag for future surprises.

How Appointment Works: Step by Step

Appointing an EU authorised representative is a structured process. Here is a practical step-by-step guide based on current regulations and provider practices:

1. Determine your need: Confirm that you are a non-EU manufacturer and that your products require CE marking or fall under specific EU regulations (e.g., medical devices, electronics, toys).
2. Choose a provider: Select a representative established in the EU. Verify their legal entity, published address, and registration details.
3. Request written terms: Obtain a written mandate that clearly states the scope (e.g., Article 18 duties), renewal price, and all exclusions. For REP27, this includes a verifiable certificate and public verification page.
4. Sign the mandate: The provider issues a designation letter, often with an eIDAS electronic signature. You may need to provide your technical documentation and declaration of conformity at this stage.
5. Update compliance files: Add the representative’s details to your product labels, technical documentation, and any required declarations. For Amazon and other marketplaces, update the Seller Central or equivalent record.
6. Ongoing compliance: The representative holds your documentation and responds to requests from EU authorities. You remain responsible for product safety, conformity assessment, and incident reporting.

Checklist for today:

1. Confirm your non-EU status and product type.
2. Check if your product falls under CE-marking or specific EU regulations.
3. Request written scope and renewal terms from provider.
4. Verify legal entity and certificate process.
5. Sign mandate and update your compliance files.
6. Prepare your technical documentation and declaration of conformity.
7. Monitor for regulatory updates and maintain documentation for at least ten years.

Following these steps ensures you meet all procedural requirements and avoid costly compliance gaps.

Risks, Fines, and What Providers Usually Do Not Say

Failing to appoint an EU authorised representative exposes non-EU manufacturers to significant risks:

• Market access denial: Your products may be stopped at EU borders or removed from the market if you cannot demonstrate a valid representative mandate.
• Regulatory fines: While specific fines for product law breaches depend on the regulation, GDPR Article 83(4)(a) provides an example: up to €10 million or 2% of worldwide turnover for failing to appoint a representative for data processing. Product law fines can also be substantial, and authorities may recall or block non-compliant products.
• Enforcement actions: EU market surveillance authorities may initiate investigations, request documentation, or require corrective actions. Delays in response can lead to further penalties or reputational harm.

What providers usually do not say:

• Notice periods: Many contracts include minimum notice periods for termination or switching, which can lock you in for a year or more.
• Limits on liability: The representative’s liability is typically limited to procedural failures; the manufacturer bears all legal responsibility for product safety and compliance.
• Per-request fees: Some providers charge for each authority or data subject request handled. REP27 does not state any such fees, but most competitors do not publish this information.
• Unresponsive providers: If your representative fails to respond to authorities, your products may be suspended or withdrawn. Always ask about response times and escalation processes.

To mitigate these risks, choose a provider with transparent pricing, clearly stated exclusions, and a verifiable certificate process. Always keep your documentation up to date and be proactive in monitoring regulatory changes.

Decision Matrix: Do You Need an EU Authorised Representative?

Use this decision matrix to determine if you need an EU authorised representative for your products:

Practical examples:

• US SaaS company: Needs Article 27 GDPR representative for data, not a product authorised representative unless selling hardware.
• Chinese Amazon seller: Needs EU authorised representative for product compliance (mandated by Amazon), and possibly Article 27 GDPR representative if processing EU buyer data outside Amazon.
• UK online shop selling CE-marked electronics: Needs EU authorised representative for products, and Article 27 GDPR representative for buyer data if processing it directly.

Always verify your obligations based on your business model, product type, and data processing activities.

Realistic Scenarios: What Applies and Simplest Route

Here are three realistic scenarios to illustrate which obligations apply and the simplest compliant route:

• Scenario 1: US SaaS company selling only software to EU customers
  You do not need an EU authorised representative for CE-marked products, as you are not placing physical goods on the EU market. However, if you process EU customer data, you do need an Article 27 GDPR representative. REP27 offers this service on a separate plan.
• Scenario 2: Chinese Amazon seller exporting electronics to the EU
  You must appoint an EU authorised representative for product compliance, as required by Amazon and EU law. This is enforced in Seller Central and on product labels. If you process buyer data outside Amazon (e.g., for marketing), you also need an Article 27 GDPR representative. REP27 can provide both on a single invoice.
• Scenario 3: UK online shop selling CE-marked toys to EU consumers
  Post-Brexit, you are considered a non-EU manufacturer. You must appoint an EU authorised representative for your products. If you collect and process EU buyer data directly (not solely through marketplaces), you also need an Article 27 GDPR representative. REP27 offers bundled services for both needs.

In all cases, the simplest compliant route is to select a provider with transparent pricing, clear documentation, and the ability to issue a verifiable certificate quickly. Always update your product labels and technical files with the representative’s details as soon as the mandate is in place.