EU Authorised Representative for Machinery: Providers, Prices & Compliance (2026)
- Regulation (EU) 2023/1230 applies from 20 January 2027 (Art. 12).
- EU authorised representative is mandatory for non-EU manufacturers.
- REP27 — Europe Services, SE: €290–890/year, designation in 24h.
- Competitor prices range from €349 to €1,500+ per year.
- Services and legal responsibilities vary—compare what's included.
- Not all exporters or sellers need this service (see matrix below).
Providers compared
| Provider | Established in | Published price | What the price includes | Best for |
|---|---|---|---|---|
| REP27 — Europe Services, SE | Czech Republic | €290–890/year (price_verified_on_source_page) | Signed designation letter, verifiable certificate, request desk, privacy notice wording, records holding. No legal advice or DPO. | Non-EU manufacturers needing fast, verifiable appointment and basic compliance |
| MyCEChecksource | United Kingdom | €349/year (price_verified_on_source_page) | EU address & certificate, liaison with authorities, 2 hours of support for one product family. | Small manufacturers with a single product family |
| Cleo Labssource | United Kingdom | From €1,500/year (price_verified_on_source_page) | Written mandate, contact details, documentation, answers to authorities, regular checks, expert review, monitoring. | Firms needing expert review, ongoing monitoring, corrective action support |
| Advena Ltdsource | United Kingdom | On request | EU AR services, guidance, opinions, professional advice on regulatory compliance. | Manufacturers seeking regulatory advice and support |
| Obelissource | Belgium | On request | Guidance for Machinery Directive/Regulation, support with technical documentation, maintenance of declaration of conformity. | Manufacturers needing guidance and document support |
| Representasource | Germany | On request | CE marking, market surveillance compliance, technical documentation management. | Companies needing CE and documentation management |
Prices as published on each provider's website on 16 October 2026, excluding VAT unless stated. Each row links to its source.
What Regulation (EU) 2023/1230 Requires (with Article Numbers)
Regulation (EU) 2023/1230, effective from 20 January 2027, is the new legal framework for machinery placed on the EU market, replacing Directive 2006/42/EC. Article 12 requires that any manufacturer established outside the EU must appoint an authorised representative (AR) located within the EU by a written mandate before placing machinery, partly completed machinery, safety components, lifting accessories, chains, ropes, or removable transmission devices on the EU market. The AR acts as the point of contact for market surveillance authorities and holds the technical documentation and EU declaration of conformity for at least 10 years after the last unit is placed on the market. Article 13 details importer obligations, ensuring that only compliant machinery is placed on the market and that all conformity assessments have been completed by the manufacturer. The AR’s details must appear on the product label and in the declaration of conformity. Non-compliance can result in customs refusal, product withdrawal, administrative penalties, and reputational harm. Market surveillance authorities, labour inspectorates, and customs enforce these rules. The appointment of an AR does not relieve the manufacturer of its legal obligations or liabilities (Art. 12(5)).
- Checklist for compliance:
- 1. Confirm your product is covered by Regulation (EU) 2023/1230.
- 2. Prepare technical documentation and the EU declaration of conformity.
- 3. Appoint an EU AR by written mandate before market entry.
- 4. Update product labels and documentation with AR details.
- 5. Provide all required documentation to your AR.
- 6. Maintain records for 10 years after last product is placed on the market.
- 7. Respond promptly to any requests from authorities via your AR.
How to Choose an EU Authorised Representative
Selecting the right EU authorised representative (AR) is crucial for compliance and risk management. The main considerations are the provider’s scope of service, price, speed of appointment, expertise, and transparency about what is and isn’t included. Some ARs, such as REP27 — Europe Services, SE, focus on efficient appointment, documentation holding, and request forwarding, but do not provide legal advice or compliance assessments. Others, like Cleo Labs and Advena, include guidance, technical reviews, or even ongoing monitoring and corrective action support, which may be essential for complex machinery or high-risk products. MyCECheck offers a basic package suitable for small manufacturers or those with a single product family, while Cleo Labs targets firms needing deeper compliance support. Always check if the provider’s published price covers multiple product families, additional support hours, or corrective action assistance, as these can incur significant extra fees. Transparency about exclusions and liability is key—request full terms before signing. Consider the provider’s experience with your product type and their ability to communicate in the languages required by your target markets. Speed of appointment may be critical if you are close to a launch deadline (REP27 offers designation within 24 hours). For companies selling on marketplaces (Amazon, Etsy, eBay), ensure your AR can provide verifiable certificates and public verification, as these platforms increasingly require proof of compliance. For B2B exporters, the AR’s ability to handle technical documentation and respond to authority requests efficiently is vital. For B2C or high-volume sellers, look for ARs with robust request desks and multilingual support.
| Provider | Included | Not Included | Extra Fees |
|---|---|---|---|
| REP27 | Designation letter, certificate, request desk, records | Legal advice, DPO, compliance assessment | None stated |
| MyCECheck | EU address, certificate, 2h support | Ongoing compliance, multi-family support | On request |
| Cleo Labs | Mandate, documentation, expert review | On request | On request |
| Advena Ltd | Guidance, advice | On request | On request |
| Obelis | Guidance, documentation | On request | On request |
| Representa | CE marking, documentation | On request | On request |
What the Price Really Includes
EU authorised representative service pricing varies widely, reflecting differences in scope and depth. REP27 — Europe Services, SE offers three tiers: Base (€290/year), Standard (€490/year), and Multi (€890/year), all excluding VAT. These prices cover designation, verifiable certificate, request desk, and records holding, but do not include legal advice or compliance assessment. MyCECheck charges €349/year for one product family, which includes an EU address, certificate, liaison with authorities, and 2 hours of support; additional support or product families may cost extra (details on request). Cleo Labs starts at €1,500/year per product category, offering a more comprehensive package: written mandate, documentation management, answers to authorities, regular checks, expert review, and monitoring—suitable for manufacturers needing deep compliance or corrective action support. Advena Ltd, Obelis, and Representa do not publish prices; their services include guidance, technical documentation support, and CE marking management, with fees available on request. When comparing providers, scrutinise what is included at each price point: basic ARs may only forward requests and hold documents, while premium ARs may actively review your files, advise on compliance, or coordinate with authorities. Always ask about extra charges for additional product lines, support hours, or corrective actions, as these can add up quickly. For most non-EU SMEs, a basic AR suffices if technical documentation is already complete and no ongoing compliance advice is needed. For larger firms or those with complex machinery, investing in a provider with technical review and monitoring may be prudent.
Hidden Costs and Exclusions
Understanding what is not included in your authorised representative’s service is as important as knowing what is. REP27 — Europe Services, SE clearly states that legal advice, DPO services, and compliance assessments are not provided; their role is to forward requests and hold records, not to answer on the merits or provide regulatory interpretation. MyCECheck’s base price covers only one product family and 2 hours of support; additional support or product families may incur extra fees, though these are not published. Cleo Labs includes expert review and monitoring, but the extent and frequency of these services, as well as any per-request or corrective action charges, are not detailed and should be clarified before engagement. Advena Ltd, Obelis, and Representa do not specify exclusions or extra fees on their websites, so it is essential to request full terms and conditions. Common hidden costs across the sector include charges for additional product families, technical file review, document translation, corrective actions after a market surveillance request, or urgent response fees. Notice periods for termination, liability caps, and per-request charges are often buried in contracts. Some ARs may limit their liability to the annual fee paid or exclude liability for consequential losses. Always request a sample contract and clarify all exclusions and fee triggers before signing. For companies selling on multiple marketplaces or with a broad product range, ensure your AR’s price and scope cover all required categories and compliance scenarios.
What providers usually do not say:
- REP27: No legal advice, DPO, or compliance assessment; only forwards requests.
- MyCECheck: Support limited to 2 hours; extra charges possible for more families or support.
- Cleo Labs: Regular checks and expert review may be at extra cost or frequency-limited.
- Advena, Obelis, Representa: Pricing, exclusions, and liability terms are unpublished—request in writing.
How Appointment Works: Step by Step
- Initial assessment: Confirm your product is within the scope of Regulation (EU) 2023/1230 (machinery, partly completed machinery, safety components, etc.).
- Provider selection: Compare AR providers based on your needs (price, scope, speed, technical support).
- Contact and documentation: Reach out to your chosen provider. You will need to supply company details, product information, and technical documentation (EU declaration of conformity, risk assessment, technical file).
- Written mandate: Sign a written mandate appointing the AR, as required by Article 12. This formalises the AR’s authority to act on your behalf in the EU.
- Designation and certificate: The AR issues a signed designation letter and, if offered, a verifiable certificate (REP27 provides both within 24 hours).
- Label and document update: Update your product labels, declaration of conformity, and technical documentation to include the AR’s name and address. This is mandatory for market access.
- Record transfer: Provide the AR with all required technical files and declarations for record-keeping and presentation to authorities upon request.
- Ongoing compliance: Maintain communication with your AR. Respond to requests from EU authorities or data subjects via the AR’s request desk. Update documentation as needed for design changes or regulatory updates.
- Renewal and review: Most AR contracts renew annually. Review your provider’s performance and update your mandate if your product range or compliance needs change.
This process ensures you meet all legal requirements before placing machinery on the EU market and avoids costly delays or enforcement actions.
Risks, Fines, and Enforcement
Failure to comply with Regulation (EU) 2023/1230 can have severe consequences for non-EU manufacturers. If you do not appoint an authorised representative, your products may be stopped at EU customs, refused registration, or withdrawn from the market by surveillance authorities. National authorities—including labour inspectorates and environmental agencies—have the power to investigate, demand documentation, and enforce corrective actions. Administrative penalties can include fines, product recalls, and loss of distribution channels. For GDPR Article 27 (where relevant), fines can reach EUR 10 million or 2% of worldwide turnover. For machinery, enforcement is particularly strict for safety-related failures (e.g., missing CE marking, inadequate guarding, or incomplete technical files), with potential for prosecution in cases of injury or non-compliance. Marketplaces such as Amazon and eBay may delist products lacking a valid EU AR or verifiable certificate. The AR’s role is to forward requests and documentation, but legal responsibility for compliance remains with the manufacturer. If your AR is unresponsive or unable to provide documentation, you risk immediate enforcement action. To mitigate these risks, choose a reputable AR, maintain up-to-date documentation, and ensure clear communication channels. Regularly review your compliance status and be prepared to act quickly if authorities raise concerns. For high-risk machinery or products subject to additional regulations (e.g., engine emissions, noise limits), ensure your AR is equipped to handle complex documentation and authority requests.
Decision Matrix: Who Needs an EU Authorised Representative?
| If you are … | You need an EU AR? | Notes |
|---|---|---|
| Non-EU manufacturer selling machinery in EU | Yes | Mandatory under Reg. 2023/1230 Art. 12 |
| EU-based manufacturer | No | Not required |
| Importer/distributor in EU | No (but has separate duties) | See Art. 13 |
| Non-EU company selling only via EU importer | No (importer is responsible) | If importer acts as manufacturer |
| Amazon/Etsy/eBay seller outside EU shipping direct | Yes | Marketplace may require AR details |
| B2B exporter with EU distributor | Depends | If distributor imports under own name, AR may not be needed |
Use this matrix to determine if you need an EU AR. If in doubt, consult with your chosen provider or a regulatory expert.
Realistic Scenarios
- US SaaS company selling machinery controls: A US-based company develops and sells electronic control units for industrial machinery, shipping directly to EU customers. As a non-EU manufacturer placing machinery on the EU market, it must appoint an EU AR under Regulation (EU) 2023/1230. REP27 or MyCECheck can provide fast, basic compliance; Cleo Labs is suitable if technical review or ongoing monitoring is needed. The company must update its documentation and labels with the AR’s details and provide all technical files for record-keeping.
- Chinese Amazon seller of garden machinery: A Chinese manufacturer sells robotic lawnmowers and chainsaws directly to EU consumers via Amazon. The seller must appoint an EU AR, include the AR’s name and address on all labels and declarations, and ensure technical documentation is available for 10 years. REP27 offers fast designation and verifiable certificates, which are increasingly required by marketplaces. MyCECheck is suitable for sellers with a single product family; Cleo Labs may be needed if the product is high-risk or subject to frequent authority requests.
- UK online shop with own-brand power tools: A UK-based retailer imports power tools from Asia, brands them under its own name, and sells directly to EU consumers. If the retailer is the manufacturer for EU purposes (i.e., places products on the EU market under its own brand), it must appoint an EU AR. If it uses an EU-based distributor as the importer, the distributor may take on the compliance role, and an AR may not be needed. The retailer should clarify roles in the supply chain and ensure all documentation and labelling requirements are met.
When you do not need this
- EU-based manufacturers (already established in the EU)
- Non-EU exporters using an EU importer/distributor who takes responsibility
- Suppliers of hand tools without a drive system (covered by GPSR, not machinery regulation)
- B2B exporters not placing products on the EU market themselves
Frequently asked questions
When does Regulation (EU) 2023/1230 take effect?
Regulation (EU) 2023/1230 applies from 20 January 2027. Until then, Directive 2006/42/EC remains in force. All machinery placed on the EU market after this date must comply with the new requirements, including the appointment of an EU authorised representative for non-EU manufacturers.
Who must appoint an EU authorised representative under the new regulation?
Any manufacturer established outside the EU placing machinery, partly completed machinery, or safety components on the EU market must appoint an EU authorised representative by written mandate before market entry. This applies regardless of company size or sales channel.
What must appear on the product label for machinery?
The label must include the CE marking, the manufacturer's name and address, the authorised representative's name and address, the designation, series/type, serial number, year of construction, and, where applicable, the notified body number and other required markings.
How long must technical documentation be kept?
Technical documentation and the EU declaration of conformity must be kept at the disposal of market surveillance authorities for at least 10 years after the machinery is placed on the market, as required by Article 12 of Regulation (EU) 2023/1230.
What happens if I do not appoint an authorised representative?
Failure to appoint an authorised representative can result in customs refusal, product withdrawal, administrative penalties, loss of market access, and reputational damage. Market surveillance authorities enforce compliance and can initiate corrective actions or fines.
Does REP27 provide legal advice or compliance assessments?
No. REP27 — Europe Services, SE provides designation letters, certificates, and a request desk, but does not offer legal advice, DPO services, or compliance assessments. Requests are forwarded, not answered on the merits.
Are there hidden costs with EU AR providers?
Some providers charge extra for additional product families, support hours, or corrective actions. Always check the contract for exclusions, per-request fees, and liability limits before signing. Published prices may not cover all scenarios.
Can I use the same authorised representative for multiple product families?
This depends on the provider. REP27 offers a Multi tier for multiple product families at €890/year. MyCECheck’s base price covers one product family; extra families may incur additional fees. Always confirm with your provider.
Is an EU AR required for B2B-only sales?
If you are a non-EU manufacturer placing machinery on the EU market, an AR is required regardless of whether sales are B2B or B2C. If an EU importer takes responsibility, the AR may not be needed.
What is the fastest provider for appointment?
REP27 — Europe Services, SE issues designation within 24 hours, based on their official information. Other providers’ timelines are not stated; always confirm before signing if speed is critical for your launch.
Can a distributor or importer act as my authorised representative?
Yes, if they are established in the EU and accept the mandate. However, many distributors prefer not to take on this legal responsibility. Appointing a specialist AR is common and often required by marketplaces.
What documentation must I provide to the authorised representative?
You must provide the technical file, EU declaration of conformity, and any certificates or risk assessments required by the regulation. The AR must be able to present these to authorities on request and keep them for 10 years.
Sources
- Regulation (EU) 2023/1230 (Official Text) — eur-lex.europa.eu
- REP27 — Europe Services, SE (Machinery AR Service) — gdprrepresentative.com
- MyCECheck — EU Representative — mycecheck.com
- Cleo Labs — EU Authorised Representative — cleolabs.co
- Advena Ltd — EU Authorised Representative for Machinery — advenaltd.eu
- Obelis — Machinery EU Authorised Representative — obelis.net
- Representa — Machinery — eu-representa.com