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Regulation (EU) 2023/988 · Article 16
Three roles, three regulations, and a great deal of confusion sold as advice.
Providers use these terms as if they were interchangeable. They are not, and appointing the wrong one leaves the obligation unmet while you believe it is handled.
Responsible person, Article 16
This is the general product safety role: an economic operator inside the Union, named on the product, holding the documentation and cooperating with market surveillance.
It applies to consumer products broadly, whether or not they fall under a specific harmonised directive.
Authorised representative
This exists under the harmonised sector rules — machinery, medical devices, radio equipment and others — and is appointed by written mandate to carry out defined tasks on the manufacturer's behalf.
A product can need both roles at once, which is precisely where sellers assume one covers the other.
The EU importer
If a company established in the Union buys your goods and places them on the market, that importer already carries the operator obligations, and a separate appointment may be unnecessary.
This is the one case where you may genuinely need nothing from us, and we will tell you so rather than sell you a mandate you do not need.
What the designation gives you
A written mandate under Article 16, our name and address formatted for your packaging and your listing, and a verification code that resolves on a public register while the mandate is live.
Nothing here is a PDF you have to be trusted about. The code is the proof, and it works for anyone who scans it.
Proof, not paperwork
A compliance file is only worth what a stranger can confirm about it without asking you first.
That is why the appointment carries a public code rather than a signature you would have to vouch for.
Questions we are asked
Can one company hold both roles for me?
Yes, and it is usually simpler. What matters is that each role is granted by a written mandate that names the tasks, rather than assumed by association.
My EU distributor says they cover it. Do they?
Only if they are the importer placing the goods on the market, and only if that is agreed in writing. A distributor buying from another EU company is not automatically your operator.
How do I know which one my product needs?
Send us one product and the market you sell into. We will tell you plainly which roles apply, including when the answer is that you need nothing.
The expensive mistake here is not choosing wrongly, it is believing the question has been settled when nobody has actually looked at it.
Appoint us and put the block on your label today
Designation is issued the same working day the form and payment are complete. Unlimited products on every plan.
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