CE authorised representative mandate content

A CE authorised representative mandate content must clearly identify the non-EU manufacturer, the EU authorised representative, the products and applicable legislation, and the tasks delegated. A written mandate does not transfer the manufacturer’s responsibility for conformity assessment, testing, technical documentation or signing the EU declaration of conformity.

Key takeaways

A manufacturer established outside the European Union may appoint a CE authorised representative only by written mandate, where the applicable sector legislation permits or requires it.

The mandate should define the products, applicable legislation, territory and tasks assigned to the EU authorised representative.

The manufacturer remains responsible for conformity assessment, technical documentation, required testing and the EU declaration of conformity.

An authorised representative may keep specified documents, cooperate with authorities and provide information, within the mandate and applicable legislation.

A CE authorised representative and a GPSR responsible person are not automatically the same role and do not have the same legal basis.

Is a written mandate required for a CE authorised representative?

Yes. A manufacturer must appoint a CE authorised representative through a written mandate, and only where the EU measure applying to the product provides for or permits that appointment. The mandate must be specific enough for the manufacturer, representative and market-surveillance authority to understand who is responsible for which task.

The EU framework distinguishes the manufacturer from the authorised representative: a manufacturer may appoint an authorised representative by written mandate to carry out specified tasks. Decision No 768/2008/EC on a common framework for the marketing of products and the European Commission’s 2022 Blue Guide on the implementation of EU product rules explain this approach in the CE-marking framework.

A mandate is not implied by a subscription, invoice, EU address or commercial relationship. Both parties must accept it, and it must apply to a specific legal entity. In practice, a distribution agreement or arrangement with a fulfilment provider does not by itself create an authorised representation.

Example: a US manufacturer sells wireless chargers under its own brand. Before appointing an authorised representative in the EU, it must establish whether the legislation applying to the product, including the Radio Equipment Directive and potentially electromagnetic-compatibility rules, provides for that appointment. It cannot simply print the name of a European company on the packaging without a mandate and a workable document process.

To identify CE legislation that may apply before drafting the mandate, use the CE marking guide for EU manufacturers and sellers. If you already sell online, the marketplace product compliance scanner can also flag traceability and compliance information to check before publication.

How do you check whether your product can or must have a CE authorised representative mandate?

Start by classifying the product and identifying the sector rules that cover it. An authorised representative is not a general requirement for every product sold in Europe: whether one is needed depends on the applicable harmonised legislation and the manufacturer’s situation.

CE marking applies only to product categories covered by EU harmonised legislation. The European Commission confirms this principle in its official guidance on CE marking. A consumer product that is not subject to a specific CE measure may fall under the GPSR, but that does not make it a product requiring a CE authorised representative mandate.

Identify the legislation that applies to the actual product

Assess the product’s function, components, intended use and risks rather than relying on its commercial name. One electrical product can fall within more than one legal instrument. Radio equipment, for example, may be covered by Directive 2014/53/EU on radio equipment, while electrical equipment may also be covered, depending on its nature, by Directive 2014/35/EU on low-voltage electrical equipment or Directive 2014/30/EU on electromagnetic compatibility.

A common mistake is to seek a mandate before identifying the legal manufacturer and the applicable legislation. The manufacturer is the person or company that makes a product, or has it designed or manufactured, and markets it under its name or trade mark. An importer that applies its own brand may, depending on the facts, take on the manufacturer’s role under the applicable rules.

If you are launching a first product or shipping from Shenzhen to an Amazon FBA warehouse in Germany, an EU market-entry compliance assessment can organise the CE, GPSR, customs and VAT checks to review. It flags matters to verify; it does not replace the product-specific legal or technical assessment.

Check whether an EU-established economic operator is needed

For products within its scope, Regulation (EU) 2019/1020 on market surveillance and compliance of products requires an economic operator established in the Union to be responsible for certain tasks before products are placed on the market. That operator may be the manufacturer, importer, authorised representative or, in some circumstances, a fulfilment service provider.

This does not mean that every EU-established operator automatically becomes your CE authorised representative. The selected role, legal tasks and labelling must reflect the real arrangement. Check the sector legislation and, if there is uncertainty, consult the competent authority or a suitably qualified professional.

EU Seller Kit — Where applicable legislation permits CE representation based on a written mandate, use the CE authorised representative service. It becomes active only after acceptance, entity assignment, a signed mandate and active payment.

What must CE authorised representative mandate content include?

Effective CE authorised representative mandate content identifies the parties, products and delegated tasks without ambiguity. It should also expressly exclude duties that remain with the manufacturer, so that authorities, marketplaces and internal teams do not misunderstand the representative’s role.

Identify the parties and signing authority

State the legal name, address and contact details of the non-EU manufacturer and the EU-established authorised representative. Specify who signs for each entity and in what capacity. Where a brand owner, parent company and separate factory are involved, make clear which entity is the regulatory manufacturer.

Include an effective date, termination arrangements and how documents will be handled when the mandate ends. An authority should be able to establish whether the mandate was active when the relevant product was placed on the market.

Define the products and legislation covered

Describe products by reference, model, family or another stable identifier. Add an updateable schedule where needed. A broad phrase such as “all products under the brand” is risky where product ranges have different features or are subject to different legislation.

The mandate should also name the CE legislation it covers. For a toy, for example, Directive 2009/48/EC on the safety of toys is a key legal instrument. For an electronic product, the combination of legislation depends on its functions and technical characteristics.

Set out territory, languages and sales channels

State whether the mandate covers the whole European Union and, where relevant, the countries in which products will be distributed. Great Britain is not part of the European Union, so an EU representation arrangement does not by itself meet British requirements.

Mention sales channels where that helps organise information: direct sales, import by a distributor, FBA warehousing, an online shop or a marketplace. This does not alter the underlying legal obligations, but it helps coordinate product listings, packaging and information requests.

For more detail on clauses and boundaries, read our guide to the role and limits of a CE authorised representative.

Which tasks can you delegate to a CE authorised representative?

A mandate may assign administrative and cooperation tasks provided for by the applicable legislation. It must not use a general clause to give the representative responsibilities that EU law reserves for the manufacturer.

Possible tasks depend on the sector measure. They may include:

keeping the EU declaration of conformity and, where the legislation requires it, technical documentation available to authorities;
providing documents or information to a competent national authority following a reasoned request;
cooperating with market-surveillance authorities on action taken to eliminate or reduce a product risk;
receiving and managing requests concerning products within the mandate’s scope;
displaying the representative’s contact details where applicable legislation requires or provides for this.

Keeping documents does not necessarily mean that the representative writes them or commissioned the testing. The manufacturer must provide usable access to current versions. An inaccessible archive held only by a factory with no available contact will not work when an authority requests a file.

Imagine that a market-surveillance authority requests the EU declaration of conformity for radio equipment and elements of its technical documentation. The representative may be responsible for responding and coordinating the submission. However, if the risk assessment is incomplete or test reports do not match the model being sold, the underlying issue remains with the manufacturer and its conformity system.

Your CE technical documentation should be prepared before placing a product on the market. Do not try to reconstruct it after an authority has made a request.

Which obligations remain with the non-EU manufacturer?

The manufacturer retains the core compliance obligations. Appointing an EU authorised representative can make contact and document-availability tasks more manageable, but it does not transfer the conformity decision or the responsibility to create the supporting evidence.

The manufacturer must, in particular:

identify the applicable legislation and conformity-assessment procedure;
design and manufacture the product in accordance with applicable requirements;
carry out, or arrange, the necessary assessments, testing and controls;
draw up and maintain technical documentation;
draw up and sign the EU declaration of conformity;
affix CE marking once the conditions are met;
maintain appropriate traceability and address identified non-compliance or risks.

The 2022 Blue Guide explains that an authorised representative cannot take on obligations that belong exclusively to the manufacturer, including obligations connected with product design and manufacture. The consequence is practical: a representative cannot retrospectively validate a poorly tested product or sign a declaration that the manufacturer cannot substantiate.

Another frequent misunderstanding is to confuse an authorised representative with a notified body. Where a conformity-assessment procedure requires a notified body, an authorised representative does not replace it. Check when a notified body is required for CE marking before selecting your procedure.

The EU declaration of conformity must match the product actually placed on the market, the applicable legislation and the standards or other references used. Our guide to the EU declaration of conformity: content, signature and documents helps you check that alignment.

Which documents should you provide before signing the mandate?

Give the representative a file complete enough to perform the agreed tasks and respond to authorities within the mandate’s limits. The exact list depends on the product and legislation, but it should be ready before sale, not only when an inspection begins.

Core documents to organise

For each clearly defined reference or product family, prepare at least:

manufacturer identity, technical contact details and a list of covered models;
a signed, current EU declaration of conformity;
technical documentation, or secure arrangements for access to it;
risk assessment, design specifications and relevant test reports;
instructions, warnings and safety information in the languages required for the intended markets;
images of the product, packaging, CE marking and economic-operator details;
procedures for complaints, incidents, corrective action and any recall;
evidence that the document version matches the version manufactured and sold.

Technical documentation must show how conformity was assessed. It is not merely a generic certificate or a test report for a different model. If a supplier gives you incomplete, contradictory or product-unrelated documents, request clarification before ordering. Supplier Check helps you centralise identity, payment and delivery information for review.

Plan for lasting access and updates

Decide who provides updated reports, component changes, software modifications and revised labelling. A seemingly small change can affect the available evidence or the legislation that applies.

Example: a manufacturer replaces the radio module in a connected device after launch. The mandate may remain in force, but the documentation and declaration must be reassessed and updated if the change affects conformity. The representative needs the relevant current versions; otherwise, it cannot properly perform its document-related role.

How does a CE authorised representative differ from a GPSR responsible person?

A CE authorised representative operates under the harmonised legislation applying to CE-marked products, while a GPSR responsible person is an EU-established economic operator for consumer products within the scope of Regulation (EU) 2023/988. The roles can overlap in one organisation, but they are neither interchangeable nor automatically combined.

Regulation (EU) 2023/988 on general product safety sets safety and information obligations for consumer products within its scope. It includes requirements relating to distance-sales information and economic operators. An online product listing may therefore need safety and traceability information even where the product also bears CE marking.

Point	CE authorised representative	GPSR responsible person
Legal basis	Applicable sector-specific CE legislation	Regulation (EU) 2023/988
Purpose	Mandated tasks within the CE framework	Safety and cooperation for relevant consumer products
Appointment	Written manufacturer mandate, within the applicable legislation	EU-established economic operator under the GPSR
Effect	Does not replace the manufacturer’s core duties	Does not replace the manufacturer’s duties

Having a CE authorised representative does not remove the need to assess GPSR obligations. Conversely, a GPSR responsible person does not become a CE authorised representative merely because its details appear on a product listing. To separate the roles in your situation, read the guide to the GPSR responsible person’s role and operation.

EU Seller Kit — If you need to compare the roles before appointing an operator, see the EU representation services overview. For consumer products covered by the GPSR, the GPSR responsible person service becomes active only after product review, entity assignment, a signed mandate and active payment.

How do you prepare CE representation activation without mistakes?

Prepare product conformity first, then formalise the representation. This order avoids signing an overly broad mandate, submitting an incomplete file or displaying contact details for a role that is not actually active.

Checklist before activating CE representation

In practice, do not publish a representative’s details until the relationship is active and the relevant products have been accepted within the agreed scope. A marketplace may request compliance information, but providing an address without a mandate or accessible documentation can create inconsistencies during a review.

If you sell on Amazon, eBay, Etsy, Shopify or another platform, use the marketplace compliance scanner immediately before publication to check traceability and safety information in the listing. For products made outside the EU, our guide to non-EU manufacturer and CE authorised representative obligations supports this preparation.

Tools and services to take action

EU Market Entry Compliance Assessment — Use this before a first shipment, or when you do not yet know which CE, GPSR, customs and VAT obligations require review.
CE Authorised Representative — Use this where a non-EU manufacturer needs authorised representation based on a written mandate within the limits of applicable legislation.
GPSR Responsible Person — Use this when a consumer product requires an EU-established responsible economic operator under the GPSR.
Marketplace Product Compliance Scanner — Use this before publishing or correcting a listing to identify compliance and traceability information to verify.
EU Seller Kit pricing and plans — Review available SaaS plans and add-on services relevant to your situation.

Frequently asked questions

Can a CE authorised representative sign the EU declaration of conformity instead of the manufacturer?

No. The EU declaration of conformity remains the manufacturer’s responsibility, and the manufacturer must be able to demonstrate that the product meets applicable requirements. A mandate may allow the representative to retain or provide the declaration, but it does not transfer conformity assessment or responsibility for drawing it up.

Is an EU importer automatically a CE authorised representative?

No. Importer and authorised representative are distinct roles with separate legal bases and duties. An importer becomes an authorised representative only if it has been formally appointed under a written mandate in the circumstances allowed by the applicable legislation.

Can the same provider act as CE authorised representative and GPSR responsible person?

That may be possible depending on the product, applicable legislation and the provider’s organisation, but each role must be assessed separately. Each needs a clear scope, an EU-established entity and, for the relevant service, effective activation under the applicable conditions.

Does a CE mandate automatically cover the United Kingdom?

No. Great Britain has a separate framework from the European Union. Check the UK requirements for the product, its marking and any local operator before assuming that an EU arrangement covers that market.

Must you provide the entire technical file to the authorised representative?

The applicable legislation and mandate determine the precise arrangements, but the representative must have the documents, or reliable access to the documents, needed for its tasks. Secure access, controlled versions and named contacts are often more workable than a one-off transfer of files that are never updated.

What should you do if the product changes after the mandate is signed?

Assess the effect of the change on conformity, technical documentation, testing, the EU declaration of conformity and the mandate’s scope. Tell the representative promptly if references, characteristics, documents or risks change; a new model may require a formal update or extension of scope.

Official sources

Decision No 768/2008/EC on a common framework for the marketing of products — the EU reference framework for manufacturer and authorised-representative roles.
Commission Notice: The Blue Guide on the implementation of EU product rules (2022) — practical guidance on economic operators, CE marking and the limits of a mandate.
Regulation (EU) 2019/1020 on market surveillance and compliance of products — EU-established economic-operator requirements for products within its scope.
Directive 2014/53/EU on radio equipment — rules applying to radio equipment.
Directive 2014/35/EU on low-voltage electrical equipment — low-voltage electrical safety requirements.
Directive 2014/30/EU on electromagnetic compatibility — electromagnetic-compatibility requirements.
Directive 2009/48/EC on the safety of toys — toy safety and conformity requirements.
Regulation (EU) 2023/988 on general product safety — the GPSR framework for relevant consumer products and distance-sales information.

This content provides general information and is not legal advice.