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REP27 · Services · EU representation

Article 27 · Article 16 · UK GDPR · scope of service

EU representation services, with the boundary drawn first.

Representation is a small, defined statutory role sold in a market that prefers to sound larger. The result is that buyers cannot compare offers: one provider quotes €290 and another €2,400 for what turns out to be the same one-page designation, with advisory work wrapped around it in the second case. This page states exactly what the service is, what it is not, and the four questions that separate a real provider from an address that forwards post.

Article 27Article 16 GPSRUK GDPRRecord of processingEight languagesFrom €290

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What is included, and what belongs to someone else

What EU representation services include and which services belong to other providers
What EU representation services include and which services belong to other providers

The bottom three rows matter more than the top five. A provider that will not tell you plainly what sits outside the scope has not thought about the scope, and you find out during an incident rather than during a sales call.

The three services people mean by the same phrase

ServiceLegal sourceWhat you getPrice with us
EU representativeArticle 27 GDPRContact point in the Union, record of processing, request deskFrom €290 a year
GPSR responsible personArticle 16 Regulation 2023/988Named operator on the label, technical file held, authority cooperationFrom €290 a year
UK representativeUK GDPRThe same role for the United Kingdom, through REP27 LTD€100 added to the EU plan
All threeThree regulationsThree designations, three certificates, one renewal date€890 a year
Anyone offering one document that covers the Union and the United Kingdom together is describing something that does not exist: they are separate statutes requiring establishment in separate territories.

What the service does, day to day

  1. Receives

    Letters and emails from supervisory authorities, market surveillance and consumers, at an address published in your privacy notice or printed on your product.

  2. Logs

    Each request with a date and reference. This is what turns a scattered exchange into a file you can show two years later.

  3. Holds

    The Article 30 record of processing activities, and for product work the declaration of conformity and technical documentation for ten years.

  4. Answers procedurally

    Acknowledgement within the deadline, in the language the request arrived in. Silence at this stage is recorded as non-cooperation, which is heavier than the original complaint.

  5. Forwards

    To you, the same working day. The substantive decision stays with you: you are the controller, or the manufacturer.

Four questions before you buy

Four questions to ask any EU representation provider before signing
Four questions to ask any EU representation provider before signing

Our answers, for the record: Europe Services, SE, IČO 03571785, registered in Prague since 2018; certificate with a verification code on a public page; requests logged the day they arrive and forwarded the same working day in eight languages; renewal at €240, lower than the entry price.

Why the prices differ so much

The statutory role is identical whoever performs it. The price gap comes entirely from what is bundled around it, and it is worth knowing which bundle you are buying.

ModelTypical priceWhat you are actually paying for
Designation only€250-350 a yearThe mandate, the certificate, a working contact point
Designation plus tooling€500-900 a yearA dashboard, templates, sometimes a records tool
Compliance package€1,500-3,000 a yearAdvisory hours, gap analysis, policy drafting
Law firm retainer€2,500 and upLegal advice, with the designation as an add-on
Cheapest offersUnder €150Usually an address, with nobody committed to answering
Ours is the first row deliberately. If you need the third or fourth, buy them from a firm that does that work properly, and keep the designation separate.

Switching provider, and what it involves

No gap, ever

The new designation is signed first, the privacy notice updated the same day, and only then the previous arrangement terminated.

What to ask the old provider

The request log and any correspondence they hold. It belongs to your file, not to theirs.

What changes publicly

One paragraph in your privacy notice, and on the label if the product side moves too.

What it costs

The switch price rather than the full one: €240 for Base, €390 Standard, €690 Multi.

How long

The same 24 hours as a first appointment. The paperwork is identical.

What we ask you

Nothing about why you are leaving. It is not our business and it does not change the price.

What happens when an authority actually writes

This is the scenario the whole service exists for, and it is worth walking through once before you need it. The sequence below is the one we run, and it is the same whether the letter comes from Prague, Dublin or Warsaw.

StepWhat happensTiming
ArrivalThe letter or email reaches the address published in your privacy noticeDay zero
LoggingRecorded with a date and a reference the authority can quote backSame day
AcknowledgementA procedural reply in the language it arrived in, confirming receipt and the route to youSame day
ForwardingThe full request reaches your inbox with our summary in EnglishSame working day
RecordsIf the Article 30 record is requested, we produce the copy we holdWithin the deadline
SubstanceYou decide the answer; we transmit it and keep the thread in the fileYour timeline

Nothing in that sequence requires legal expertise from us, and that is deliberate. The value is that somebody reliably does it, in the right language, within the deadline, and keeps a record that can be produced two years later. Companies that buy on price alone usually discover that the missing part is not advice: it is the first three rows.

Representation and the rest of your compliance

A designation is one obligation among several, and it is worth seeing where it sits so you neither overbuy nor assume it covers more than it does.

What representation covers

Being reachable inside the Union, holding the record of processing, cooperating with authorities. That is the statutory perimeter.

What sits next to it

Your privacy notice, your lawful bases, your processor contracts, your retention periods, your security measures. Yours to run.

What sits above it

A DPO where Article 37 requires one, and a governance programme in regulated sectors. Different budget, different supplier.

What sits beside it for products

The Article 16 responsible person, technical documentation, CE marking where sector rules apply, and packaging registration per country.

What nobody can outsource

Deciding what you collect and why. The regulation puts that with the controller and leaves it there.

Where we stop

At the edge of the mandate, deliberately, and we say so before you pay rather than after something arrives.

Questions we are asked by finance teams

Representation is usually bought by a compliance or operations lead and approved by finance. These are the five questions finance asks, with the answers written for them.

  1. Is it a recurring cost?

    Yes, annual, for as long as you reach the Union without an establishment there. It ends the day either fact changes.

  2. Does the price scale with volume?

    No. It does not scale with revenue, SKUs, marketplaces or number of requests. One designation, one price.

  3. What is the downside of not buying it?

    Article 83(4)(a): up to €10 million or 2% of worldwide turnover, plus the commercial cost of failing vendor assessments.

  4. Can we invoice it to a group entity?

    Yes, and we issue separate designations per legal entity on one invoice where a group needs several.

  5. What are we locked into?

    Twelve months, terminable on notice. There is no multi-year commitment and no penalty for leaving.

The honest case against buying this

Selling something means saying when not to buy it. Four situations where representation is the wrong purchase, written plainly because a designation you do not need is waste on your side and churn on ours.

SituationWhy you do not need itWhat to do instead
You have a real EU establishmentArticle 27 applies to controllers outside the Union. Establishment removes the questionDocument who the controller is and keep it current
You are a public authorityArticle 27(2)(b) exempts public authorities and bodiesNothing, on this point
You do not reach the UnionNo offering, no monitoring, no Article 3(2)Write down the analysis and date it
You sell only through an EU importerThe importer places the goods on the market and carries the product dutiesCheck whether the data side still reaches you

The last row is the one worth reading twice, because it is only half an exemption. An importer takes on the product obligations under Article 16 and nothing at all under Article 27. A manufacturer selling FOB to a European distributor may still be processing the personal data of people in the Union through its own website, its newsletter or its support desk, and that part of the analysis has to be run separately. We would rather tell you that now than sell you a plan and discover the mismatch during an audit.

There is also a fifth case that comes up often enough to name: the company that will need representation in three months but not today, because the European launch has not happened. The correct answer there is to wait. A designation signed before the first EU customer exists is a year of coverage spent on nothing, and the appointment takes 24 hours whenever you are ready.

Reviewing the scope of an EU representation service before signing
Reviewing the scope of an EU representation service before signing
Request desk handling correspondence for a represented company

Questions we are actually asked

What exactly is an EU representation service?

A written designation under Article 27 GDPR naming a company established in the Union as your contact point for supervisory authorities and data subjects, with the record of processing activities held on your behalf.

Is it the same as a compliance consultancy?

No. A consultancy advises you. A representative receives correspondence, holds records and cooperates with authorities. Many companies need both, from different providers.

Does the service include legal advice?

No, and any provider including it at these prices is not really providing it. We supply the designation, the certificate, the wording and the desk.

Can one provider cover the EU and the UK?

Not with one document. It takes two designations from two entities established in the two territories. We issue both, on one invoice.

Does it cover product safety?

Only if you buy the Article 16 responsible person as well. Data and products are separate regulations with separate designations.

What is the record of processing activities?

The Article 30 record listing what you process, why, for whom and with which recipients. The representative holds it and produces it to authorities on request.

How fast can representation start?

Signed within 24 hours of a completed form, with a certificate carrying a verification code and the paragraph for your privacy notice.

Do you handle data subject requests for us?

We receive, log and forward them the same working day, and answer procedural questions. The substantive decision on each request stays with you as controller.

What languages do you work in?

Eight, which covers the languages requests actually arrive in. A data subject may write in the official language of their own Member State.

Does representation reduce our liability?

No. Article 27(5) preserves proceedings against the controller or processor. Any promise to the contrary describes something the regulation does not permit.

What happens if we stop selling into the Union?

Tell us and we terminate rather than renew. There is no benefit to you in keeping a designation you no longer need.

Can we see the mandate before paying?

Yes. Ask and we send the template. It is one page and every clause has a purpose.

Do you serve processors as well as controllers?

Yes, on the same terms. Agencies and software houses processing for EU clients are caught by Article 3(2) directly.

Is a virtual office the same thing?

No. A virtual office forwards post. A representative accepts statutory tasks in writing and answers for them.

What does the certificate prove?

That a named entity established in the Union has accepted the role for your company, verifiable by a third party without contacting you.

What is not included, in one line?

Legal advice, DPO duties, policy drafting, product testing, CE marking, packaging registration and any transfer of your liability.

Do you charge per marketplace or per product?

No. One designation covers your whole catalogue and every European marketplace.

What happens at renewal?

One invoice at the lower renewal price, one expiry date, and a reminder before it falls due rather than after.

Related: how to choose a provider · what it costs

Representation with the boundary in writing

Europe Services, SE in Prague, signed within 24 hours, with a verifiable certificate, the record of processing held for you and a desk that answers in eight languages.

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