Who Can Act as EU Authorised Representative Under Article 4 of Regulation 2019/1020?

• Article 4 requires a legal entity in the EU as authorised representative.
• Eligible: manufacturer, importer, authorised representative, or fulfilment provider (Art. 4(2)).
• REP27 — Europe Services, SE: €490/year, written mandate, certificate, request desk.
• Competitor prices often on request; always check renewal terms.
• Service excludes conformity assessment, legal advice, and product testing.
• Non-EU sellers on Amazon, Etsy, eBay typically need this for market access.

Updated 16 October 2026 · 5 sources checked

Providers compared

Prices as published on each provider's website on 16 October 2026, excluding VAT unless stated. Each row links to its source.

What Article 4 of Regulation 2019/1020 Requires

Regulation (EU) 2019/1020, specifically Article 4, sets out a crucial requirement for non-EU businesses selling certain products into the EU market, especially via online channels. The regulation mandates that, for a wide range of harmonised products (including machinery, EMC, low voltage, radio equipment, RoHS, and more), there must be an economic operator established in the EU responsible for compliance and communication with authorities.

• Who can be the economic operator? Article 4(2) allows four options: (1) a manufacturer established in the EU, (2) an importer, (3) an authorised representative with a written mandate, or (4) a fulfilment service provider established in the EU. For non-EU manufacturers selling online, appointing an authorised representative is the most practical route.
• What are the duties? Article 4(3) lists key tasks: ensuring the Declaration of Conformity and technical documentation are available, cooperating with market surveillance authorities, and informing authorities about product risks. The operator’s name and contact details must appear on the product, packaging, or documents (Art. 4(4)).
• What are the consequences of non-compliance? Article 4(6)-(7) empowers Member States to impose penalties and restrict or prohibit non-compliant products. Article 4(8)-(9) requires cooperation with authorities and sharing information on dangerous products via the EU rapid alert system.

In practice, this means that any non-EU business selling covered products online to EU consumers must have a named, EU-based representative or risk product bans and enforcement action. The appointed entity must be able to respond to authority requests and hold compliance documentation for up to 10 years.

How to Choose an EU Authorised Representative

Choosing the right EU authorised representative is a compliance-critical decision. The provider must be a legal entity established in the EU and capable of fulfilling the duties set out in Article 4. Here’s what to consider:

• Location and legal status: The representative must be established in an EU Member State. Always verify the company’s registration details before appointing.
• Scope of mandate: The mandate should be limited to the duties allowed by law. For example, REP27’s mandate is strictly for Article 18 and does not cover conformity assessment, legal advice, or product testing. Beware of providers claiming to take on duties the law reserves for others.
• Transparency: Look for published prices, renewal terms, and a clear list of what is included and excluded. REP27 publishes both first-year and renewal prices, while many competitors do not.
• Verification and documentation: A verifiable certificate or public record of appointment is essential for customs, authorities, and marketplaces. REP27 provides a QR-verifiable certificate.
• Languages and request handling: Consider how requests from authorities and consumers are handled, and in which languages. REP27 forwards requests in up to 8 languages within 2 business days.

Below is a comparison table of inclusions, exclusions, and extra fees:

Always request all terms in writing before committing to a provider.

What the Price Really Includes

Pricing for EU authorised representative services varies widely, and many providers do not publish their rates. REP27 — Europe Services, SE is one of the few with transparent pricing: €490 per year for the Article 18 mandate, with renewal at €440, and bundled discounts if combined with other mandates (such as GDPR Article 27 or GPSR Article 16). The price covers:

• Signed written mandate (Article 18), with eIDAS electronic signature
• Verifiable certificate (QR code, public verification)
• Request desk for forwarding authority and data subject requests within 2 business days
• Retention of your Declaration of Conformity and technical file for up to 10 years

What is not included: legal advice, DPO services, conformity assessment, product testing, SBOM generation, or incident reporting. These are always the manufacturer's responsibility and must be budgeted separately. REP27 is explicit that the expensive parts of compliance (such as notified body assessment for important class II or critical products) are not included and can cost thousands of euros elsewhere.

Competitors such as Representa and Rino OU do not publish prices or detailed inclusions/exclusions; you must request a quote and clarify all terms before signing. Always ask for the renewal price, scope of mandate, and process for handling authority requests in writing.

Hidden Costs and Exclusions

EU authorised representative services are often marketed as a simple annual fee, but there are several hidden costs and exclusions to watch for:

• Conformity assessment: No representative can perform conformity assessment or product testing; this is the role of notified bodies or accredited labs, and costs can be substantial for higher-risk products.
• Legal advice: Most representatives, including REP27, do not provide legal advice or compliance assessments. Their role is to forward requests and hold documentation, not to answer on the merits or interpret regulations for you.
• Renewal pricing: Many providers do not publish renewal prices, leading to unexpected increases after the first year. REP27 is explicit about renewal rates.
• Silent renewal and notice periods: Some providers may auto-renew at a higher rate or require lengthy notice periods for cancellation. Always confirm these terms in writing.
• Per-request or document fees: Some representatives may charge extra for forwarding requests, document handling, or certificate re-issuance. REP27 does not state any such fees, but always check with competitors.
• Liability: The representative does not assume liability for product compliance; the manufacturer or operator remains responsible. Article 18(2) forbids representatives from taking on certain duties reserved for others.

In summary, always ask for a full list of exclusions, renewal terms, and any potential extra fees before appointing a provider.

How Appointment Works: Step by Step

Appointing an EU authorised representative is a structured process. Here is a step-by-step guide, including a decision matrix and practical examples:

1. Determine if your product is covered: Check if your product falls under the harmonised legislation listed in Article 4(5) (e.g., machinery, EMC, RoHS, radio equipment).
2. Identify your supply chain: Are you a non-EU manufacturer selling direct to EU consumers? Is there an EU-based importer or fulfilment provider who could act as the economic operator?
3. Shortlist providers: Choose an EU-based representative with transparent pricing and verifiable credentials. Request a written scope of service and renewal terms.
4. Sign the mandate: Complete the provider’s onboarding process, sign the written mandate (Article 18 for REP27), and provide the necessary product documentation.
5. Receive certificate: Obtain a verifiable certificate or designation letter. REP27 provides a QR-verifiable certificate within 24 hours.
6. Update product and documentation: Add the representative’s name and address to product labels, packaging, and technical files as required by Article 4(4).
7. Retain documentation: Ensure all technical documentation and Declarations of Conformity are available for at least 10 years for authorities.
8. Monitor compliance: Stay updated on regulatory changes and renewal deadlines.

Decision Matrix:

Risks and Fines

Non-compliance with Article 4 of Regulation 2019/1020 carries significant risks for non-EU businesses selling into the EU:

• Product bans: Authorities can restrict or prohibit the sale of non-compliant products (Art. 4(7)). This can result in products being seized at customs or removed from online marketplaces.
• Penalties: Each Member State sets its own penalties, but they must be effective, proportionate, and dissuasive (Art. 4(6)). Fines can be substantial and may include daily penalties until compliance is achieved.
• Market access loss: Online platforms like Amazon, eBay, and Etsy enforce the requirement for an EU authorised representative. Without one, listings can be suppressed or removed, and inventory may be blocked from reaching EU consumers.
• Reputational damage: Information about dangerous or non-compliant products is shared via the Union rapid alert system (Art. 4(8)), which can lead to negative publicity and loss of consumer trust.
• Delays and supply chain disruption: Failure to provide the correct documentation or contact details can delay customs clearance and disrupt sales cycles, especially for time-sensitive products.

In summary, appointing a compliant EU authorised representative is essential for uninterrupted access to the EU market and to avoid costly enforcement actions.

What Providers Usually Do Not Say

Many providers highlight the ease of appointing an EU authorised representative but omit important details that can impact your compliance and costs:

• Exclusions: Most do not provide legal advice, conformity assessment, or product testing. REP27 is explicit about these exclusions, but many competitors are not.
• Notice periods and silent renewal: Some providers auto-renew contracts at higher rates or require long notice periods for cancellation. REP27 publishes renewal terms upfront, but always confirm with others.
• Per-request fees: Extra charges may apply for document handling, forwarding requests, or certificate re-issuance. Always ask for a full fee schedule.
• Liability limitations: The representative does not assume liability for product compliance. Article 18(2) forbids representatives from taking on certain duties reserved for the manufacturer or operator.
• Scope of mandate: A mandate claiming to cover duties outside Article 18 may be non-compliant. Always ensure the mandate is limited to what the law allows.

Before appointing any provider, request a written list of inclusions, exclusions, renewal terms, and all potential extra fees.

Realistic Scenarios: What Obligation Applies

• US SaaS company selling IoT devices to EU consumers: The company is a non-EU manufacturer selling covered products (e.g., radio equipment) online. It must appoint an EU authorised representative under Article 4. REP27 or similar can provide the written mandate, certificate, and request desk. The company remains responsible for product compliance and technical documentation.
• Chinese Amazon seller shipping electronics to Germany: To list on Amazon.de, the seller must provide an EU authorised representative’s details in Seller Central and on the product label. The representative acts as the contact point for authorities and holds the technical file. If Amazon is the fulfilment provider and the seller never handles EU customer data, only the Article 4 mandate is required.
• UK online shop post-Brexit selling toys to France: Since the UK is no longer in the EU, the shop must appoint an EU authorised representative for its products. The representative’s details must be included on packaging and documentation. The shop remains responsible for conformity assessment and compliance with toy safety directives.

In each scenario, the simplest compliant route is to appoint a specialist provider with transparent pricing and a verifiable certificate, ensuring all documentation and labelling is updated accordingly.

Checklist: How to Appoint an EU Authorised Representative Today

1. Confirm product coverage: Check if your product falls under the harmonised legislation listed in Article 4(5) (e.g., machinery, EMC, RoHS, radio equipment).
2. Map your supply chain: Determine if you have an EU-based importer or fulfilment provider who could act as the economic operator. If not, proceed to appoint an authorised representative.
3. Shortlist providers: Compare EU-based representatives for transparency, scope, and renewal terms. Request all terms in writing.
4. Request and review the mandate: Ensure the written mandate is limited to Article 18 duties and does not claim to cover conformity assessment or legal advice.
5. Sign and pay: Complete onboarding, sign the mandate, and pay the first-year fee. REP27 issues the designation within 24 hours.
6. Receive and verify certificate: Obtain a verifiable certificate or designation letter. Ensure it can be checked by authorities or marketplaces.
7. Update labels and documentation: Add the representative’s name and address to product labels, packaging, and technical files as required by Article 4(4).
8. Retain technical documentation: Ensure all required documents are available for at least 10 years for market surveillance authorities.
9. Monitor renewal dates: Track renewal deadlines and notice periods to avoid lapses in representation.
10. Stay informed: Monitor regulatory changes and update your compliance processes as needed.