A CE authorised representative: role, limits and differences from a GPSR responsible person matter because these are separate EU product-compliance roles. A CE authorised representative acts under a written mandate within applicable CE legislation; it does not become the manufacturer. A GPSR responsible person is an EU-based economic operator for consumer-product safety. Neither role replaces the manufacturer’s evidence of compliance.
Key takeaways
- A CE authorised representative may act only within a written mandate and the CE legislation that applies to the product.
- The manufacturer remains primarily responsible for product design, conformity assessment, testing, technical documentation and, in principle, the EU declaration of conformity.
- CE marking applies only to products covered by EU harmonisation legislation; manufacture in China, the United States or Great Britain does not itself create a CE-marking requirement.
- A GPSR responsible person may be needed for a consumer product sold in the EU, but that person is not automatically a CE authorised representative.
- Before listing a product, check CE rules, GPSR duties, online product information and the requirements of each storage and destination country separately.
Who needs a CE authorised representative?
A non-EU manufacturer needs a CE authorised representative only where the applicable EU harmonisation legislation requires one, or where it permits appointment and the manufacturer wishes to delegate defined tasks. The answer turns on the product, its intended use and the sector-specific legislation.
The manufacturer is the business that makes a product, or has it designed or made, and markets it under its own name or trade mark. This status does not depend on where the factory is located. A French company having goods made in Vietnam under its brand will usually be the manufacturer; so will a Chinese company selling its own branded product.
The common framework for marketing products allows a manufacturer to appoint an EU-established authorised representative through a written mandate for specified tasks. Decision No 768/2008/EC and the European Commission’s Blue Guide on the implementation of EU product rules (2022) explain the roles of economic operators and the division of responsibilities.
The shipping country does not trigger CE marking
A product shipped from Shenzhen to an Amazon FBA warehouse in Germany does not need CE marking merely because it comes from China. It needs CE marking only if it falls within legislation that requires it, such as the Toy Safety Directive, the Low Voltage Directive, the EMC Directive or the Radio Equipment Directive for relevant radio equipment.
Before arranging representation, identify the legislation that applies to the product and your sales markets. An EU market-entry compliance assessment helps you organise the checks needed for the product, import flows, VAT, GPSR, CE marking, packaging and extended producer responsibility schemes.
Importer, distributor and marketplace seller are different roles
An importer is the EU-established operator that places a product from a third country on the EU market. A distributor makes a product available without being its manufacturer or importer. A marketplace seller may be either of these, or may sell on behalf of the manufacturer, depending on the commercial model.
These roles do not substitute for one another. The presence of a warehouse, platform or freight forwarder in the supply chain does not mean that it has accepted the role of CE authorised representative. Check your contracts and the information shown on the product every time.
What can a CE authorised representative do?
A CE authorised representative performs only the tasks set out in its written mandate, and only to the extent permitted by the applicable legislation. Typical tasks include holding documents, making them available to authorities and cooperating with authorities that request information.
Depending on the sectoral legislation, the mandate may provide that the representative:
- keeps the EU declaration of conformity and technical documentation for the required period;
- provides those documents to a market-surveillance authority following a reasoned request;
- cooperates with the competent authority on action intended to reduce a product risk;
- communicates the manufacturer’s identity and contact details where required.
The precise scope varies by legislation. For radio equipment, for example, Directive 2014/53/EU on radio equipment (RED) contains specific obligations for manufacturers and authorised representatives. For a toy, examine Directive 2009/48/EC on the safety of toys and the requirements relevant to that product.
What the representative cannot do instead of the manufacturer
A common mistake is to assume that a mandate transfers compliance. It does not. A CE authorised representative does not replace the manufacturer in:
- defining the intended use and foreseeable risks of the product;
- selecting relevant standards or assessment methods;
- carrying out, or arranging, necessary testing;
- compiling and maintaining the technical documentation;
- affixing the CE marking;
- signing the EU declaration of conformity, except where a particular legal framework and mandate expressly allow this.
Your Europe’s CE-marking guidance confirms that the manufacturer must assess product conformity before affixing CE marking. If an authority finds an incomplete file, a mandate does not retrospectively cure missing tests, analysis or technical evidence.
Use the guidance on a CE technical file and on the EU declaration of conformity to prepare the evidence that remains your responsibility.
EU Seller Kit — If you are a non-EU manufacturer of a CE-marked product, the CE authorised representative service may be appropriate where the applicable legislation permits it and a written mandate is put in place. It becomes active only after acceptance, entity assignment, a signed mandate and active payment; it does not replace your testing or technical documentation.
CE authorised representative: role, limits and differences from a GPSR responsible person
A CE authorised representative operates under sector-specific CE legislation. A GPSR responsible person is the EU-established economic operator to which a product covered by the General Product Safety Regulation must be linked. The same entity may perform both roles only where legal and contractual conditions are met; the roles are not interchangeable.
Regulation (EU) 2023/988, known as the General Product Safety Regulation or GPSR, has applied since 13 December 2024. It sets out consumer-product safety and economic-operator obligations. For products within its scope, an EU-established economic operator must be identified before the product is placed on the market where the manufacturer is not established in the EU and no other qualifying operator in the chain takes that role.
| Comparison point | CE authorised representative | GPSR responsible person |
|---|---|---|
| Main legal basis | Applicable sector-specific CE legislation | Regulation (EU) 2023/988 |
| Products covered | Products subject to CE legislation that provides for a mandate | Consumer products within GPSR scope, subject to sector-specific rules |
| Appointment | Written manufacturer mandate, within the relevant legal framework | EU-established economic operator identified for the product |
| Core limit | Does not replace the manufacturer’s compliance work | Does not make the product compliant instead of the manufacturer |
GPSR responsible persons and online sales
For distance-selling offers, the GPSR requires certain information to be accessible in the offer. This includes the manufacturer’s identity and contact details and, where the manufacturer is not established in the EU, those of the EU-established responsible person. Product identification and relevant warnings or safety information must also be presented. See the explanation of GPSR Article 19 and information to show online.
Example: imagine a US manufacturer selling a connected lamp directly to French consumers through Shopify. Depending on its features, the lamp may fall under RED, EMC and other CE requirements. Its sales listing must also be assessed under the GPSR. The manufacturer must therefore deal separately with CE conformity, any authorised-representative role and identification of the GPSR responsible operator.
A marketplace product compliance scan can flag traceability, safety and compliance information to check before publication. It does not replace a legal or technical assessment of the product.
When should you deal with representation and compliance?
Deal with representation and compliance before the first placing on the EU market, not after a listing is blocked or an authority makes its first request. Offering a product through a website, marketplace or FBA stock can expose it to checks by platforms and market-surveillance authorities.
In practice, the sequence starts before you place the supplier order. Request manufacturer documents, check the product and labelling, then determine which EU-established operators are involved. Waiting until the goods arrive can leave stock held up, a listing suspended or documents difficult to obtain within a short deadline.
Special case: stock imported into the EU
If you import stock into the EU yourself, prepare the customs and VAT side as well. An EORI number identifies operators in customs formalities; it does not appoint a CE authorised representative or GPSR responsible person. The European Commission explains the purpose of Economic Operators Registration and Identification (EORI).
For a first shipment to a warehouse in Germany, France or Spain, use the EU stock-import guide for ecommerce sellers to map the process. If you need to prepare an application file, EORI file preparation prepares the file; the number itself is issued by the competent customs authority.
Special case: a product already sold in the EU
A product already held by an EU distributor is not automatically exempt from review. Establish who first placed it on the market, under which brand, which version is being sold and whether the documents match the current product. A change in supplier, battery, radio component, material or brand can change the compliance assessment.
Market surveillance is supported by Regulation (EU) 2019/1020 on market surveillance and compliance of products. Authorities may request information and documents from the relevant economic operators.
How do you appoint the right representative step by step?
Start by qualifying the product and your role, collect the evidence, then appoint the appropriate operator before sale. Do not begin by choosing a service label; begin with the rules applying to your product.
Step 1: identify the product and manufacturer
Describe the product precisely: its function, composition, electrical supply, connectivity, intended user, target age, accessories and sales countries. Then identify the entity placing its name or trade mark on the product. That entity will often be the manufacturer in regulatory terms.
If you buy a generic product and sell it under your own brand, you may become the manufacturer even though you do not own the factory. Before ordering, use Supplier Check to centralise identity, payment and delivery information for review alongside the technical documents you request.
Step 2: identify the applicable legislation
Check whether the product is covered by CE-marking legislation, the GPSR, or both. A toy, charger, radio product or electrical appliance is not assessed in the same way as a non-electrical garment or decorative item.
For electronic products, read the guide to RED, Low Voltage and EMC Directives. For products without a specific CE regime, the GPSR may still be decisive. A product-specific risk assessment is then essential good practice; the GPSR risk-assessment method helps you structure that work.
Step 3: collect and check the documents
Collect documents before shipment: product description, risk assessment, relevant test reports, standards applied where relevant, instructions, warnings, labelling, an EU declaration of conformity where required and technical documentation.
Do not rely on a generic certificate supplied by a manufacturer. Check that the product name, reference, version, manufacturer and tested characteristics match the item you actually sell. A declaration for an older model or a report covering another battery is not sufficient evidence for your version.
Step 4: appoint the EU-established operator
Where applicable CE legislation requires or permits an authorised representative, define a precise written mandate. Where the GPSR requires a responsible economic operator in the EU, make sure the role has actually been assigned and that the contact details to display are correct.
A software subscription does not appoint a representative. The GPSR responsible person service becomes active only after product review, entity assignment, a signed mandate and active payment. Review the EU representation services overview to compare the roles before requesting either service.
Step 5: update the product and sales listings
Place the required information on the product, its packaging or accompanying documents according to the applicable rules. Prepare the product-listing information too: product identity, manufacturer, responsible operator where required, and relevant warnings and safety information.
For Amazon, Etsy, eBay, Shopify or Cdiscount sales, the listing must not contradict the labelling or supporting documents. Read Amazon GPSR compliance information for sellers if you sell on Amazon.
Checklist before your first EU sale
- I have identified the entity that is legally the product manufacturer.
- I have checked whether sector-specific CE legislation applies to the product.
- I have determined whether a CE authorised representative is required, permitted or irrelevant in my case.
- I have checked GPSR duties and the EU-established economic operator that must be identified.
- I hold documents that match exactly the reference and version being sold.
- Any representation mandate is written, signed and limited to applicable tasks.
- Labelling, packaging, instructions and the product listing contain the required information.
- I have prepared customs, EORI and VAT data if I import the stock myself.
What documents and effort should you plan for?
The main cost is often the time needed to classify the product, collect evidence and coordinate with the manufacturer. The effort depends on product complexity, technology, countries involved and the quality of documents already available.
For a simple non-electrical item, the work may centre on materials, foreseeable risks, traceability and warnings. A connected device generally needs more checks: power supply, radio functions, electromagnetic compatibility, software, instructions and consistency across test evidence.
Documents to prepare or obtain
Keep an organised, accessible version of the following:
- manufacturer and product identification, including references and versions;
- CE authorised-representative mandate or GPSR responsible-person agreement, where relevant;
- technical documentation and EU declaration of conformity for CE-marked products;
- test reports, assessments, instructions, warnings and traceability records;
- evidence of labelling and screenshots of published product listings;
- procedures for complaints, incidents and corrective action.
A mandate should not be vague. It should identify the parties, the covered product or product families, delegated tasks, cooperation arrangements with authorities and the terms for retaining or providing documents.
For service costs, plan options and available add-ons, see pricing and plans. Regulatory requirements are not merely an administrative formality: they require evidence suited to the product.
Which mistakes most often cause a blocked listing or authority request?
Problems commonly arise from confusion between roles or documents that do not match the product sold. A market-surveillance authority or platform may request specific documents quickly; an incomplete response can result in a suspended listing, a correction request or product measures.
Confusing CE, GPSR, EORI and VAT
CE marking applies to certain product categories. The GPSR concerns general consumer-product safety and identification of economic operators. EORI is for customs formalities. VAT concerns the tax treatment of transactions. None replaces the others.
If you ship stock from a third country, check the tariff code and import requirements separately. The HS classification assistant generates candidate subheadings to confirm in the Combined Nomenclature or TARIC; it is not a binding tariff decision. You can then consult the European Commission’s TARIC database to check applicable measures.
Displaying a name without a mandate or real activation
Do not publish the contact details of a CE authorised representative or responsible person if no mandate or effective assignment exists. This can create misleading information for authorities, consumers and platforms.
Likewise, do not assume a SaaS subscription automatically appoints a representative. Representation requires the conditions specific to the service and the applicable legal framework.
Using generic or outdated documents
A test report for a similar product is not necessarily usable. Changes to components, supplier, software, battery, dimensions or brand must be assessed. Keep version traceability so that you can answer a compliance request.
For possible outcomes of a check, read the guide to GPSR enforcement and penalties. Measures depend on the product, the risk, the competent authority and the facts found.
Which special cases need closer review?
Hybrid products, cross-border sales and changes in your commercial model require a closer assessment. One product reference can fall under several legal instruments, and several economic operators can appear in its route to market.
Electronic, radio and toy products
A connected toy may be subject to toy rules as well as rules covering its radio or electrical functions. A single document labelled “CE” is not enough. Identify all applicable requirements and verify that the technical file covers them.
Directive 2014/35/EU on low-voltage electrical equipment and Directive 2014/30/EU on electromagnetic compatibility illustrate this sectoral approach. Depending on the product, a notified body may or may not be required: this depends on the legislation and applicable conformity-assessment procedure, not simply on the presence of CE marking. See the guide on when a notified body is required for CE marking.
Cosmetics and other specialist regimes
Cosmetics follow their own regime. Regulation (EC) No 1223/2009 on cosmetic products provides, among other requirements, for a specific responsible person. Do not automatically equate that role with a GPSR responsible person or CE authorised representative.
Textiles, food, medical devices and other categories can also be governed by specialist rules. For textiles, examine Regulation (EU) No 1007/2011 on textile fibre names and labelling. If you are unsure about a sectoral regime, check the relevant legislation and seek advice from a qualified professional.
Selling in Great Britain and Northern Ireland
The European Union and Great Britain do not operate under the same regulatory framework. An EU EORI number does not automatically cover UK customs formalities, and representation rules may differ. Read the GB and XI EORI guide for Great Britain and Northern Ireland before arranging your flows.
Tools and services to take action
- EU Market Entry Compliance Assessment: use it before your first shipment or launch to organise checks on products, flows, VAT, GPSR, CE and connected obligations.
- CE Authorised Representative: use this where you are a non-EU manufacturer of a CE-marked product and the applicable legislation permits or requires a written mandate; it does not replace conformity assessment or technical documents.
- GPSR Responsible Person: use this where a consumer product from a non-EU manufacturer needs an EU-established responsible economic operator under the GPSR, subject to review, entity assignment, a signed mandate and active payment.
- Marketplace Product Compliance Scanner: use it before publishing or updating an Amazon, eBay, Etsy or Shopify listing to flag compliance and traceability information for review.
- EU compliance tools: use this catalogue to access HS classification, customs-cost, VAT, country-compliance and supplier-check tools for your trade flow.
Frequently asked questions
Is a CE authorised representative compulsory for every product imported from China?
No. The requirement depends on the EU harmonisation legislation applying to the product, not on its country of manufacture or dispatch. First establish whether CE marking applies, then check whether the relevant sectoral legislation requires or permits appointment of an authorised representative.
Can a CE authorised representative sign my EU declaration of conformity?
As a rule, the manufacturer remains responsible for the EU declaration of conformity and the conformity assessment supporting it. Particular legislation or mandates can provide for specific tasks, but check the applicable sectoral text and the exact mandate before delegating a signature or declaration.
Can the same company be both CE authorised representative and GPSR responsible person?
This may be possible where the entity is established in the EU, accepts both roles and meets the requirements of each. You must still put in place the mandates, assignment and documents needed for each function; one role does not arise automatically from the other.
My supplier sent a CE certificate. Is that enough?
Not necessarily. Check that it concerns your exact product, reference, version, brand and technical characteristics. CE marking rests on an appropriate conformity assessment and supporting documentation, not solely on the existence of a commercial certificate.
Must an Amazon listing show the CE authorised representative’s contact details?
The information to display depends on the product and the rules governing distance sales. For products covered by the GPSR, the online offer must include required manufacturer information and, where the manufacturer is not established in the EU, information about the EU-established responsible person; also check Amazon’s own requirements.
Does an EORI number replace a responsible person or authorised representative?
No. An EORI number identifies an operator for customs formalities. It does not prove product conformity, appoint a CE authorised representative or establish a GPSR responsible person.
Official sources
- Regulation (EU) 2023/988 — General Product Safety Regulation (GPSR) — GPSR framework, economic operators and distance-selling information.
- Regulation (EU) 2019/1020 — market surveillance and compliance of products — market-surveillance powers and cooperation.
- Decision No 768/2008/EC — common framework for the marketing of products — reference definitions and responsibilities for economic operators, including authorised representatives.
- Commission Notice — The 'Blue Guide' on the implementation of EU product rules (2022) — practical interpretation of EU product-rule implementation.
- Your Europe — CE marking — CE-marking principles and manufacturer responsibility.
- Directive 2014/53/EU — radio equipment (RED) — requirements for radio equipment and operator responsibilities.
- Directive 2014/35/EU — low voltage electrical equipment (LVD) — safety requirements for certain electrical equipment.
- Directive 2014/30/EU — electromagnetic compatibility (EMC) — electromagnetic-compatibility requirements for covered equipment.
- European Commission — Economic Operators Registration and Identification (EORI) — the role of EORI in customs formalities.
- Directive 2009/48/EC — safety of toys — safety requirements for toys.
- Regulation (EC) No 1223/2009 — cosmetic products — the specialist cosmetics regime and responsible person.
- Regulation (EU) No 1007/2011 — textile fibre names and labelling — textile-fibre labelling rules.
This content provides general information and is not legal advice.