Regulatory triage · GPSR · MDR · RoHS
Do you need an EU Authorized Representative?
Non-EU seller? Find out which of the four regimes require an EU Authorized Representative, what it costs per year, and which vetted EEA-established providers cover your category.
Regulatory citations verified 2026-08-12; provider pricing checked 2026-08-12.
Checking the age of the data…
Do non-EU sellers need an EU Authorized Representative?
Yes — in most cases. Since the General Product Safety Regulation (EU) 2023/988 started to apply on 13 December 2024, a product covered by it may not be placed on the EU market unless there is an economic operator established in the Union responsible for it (GPSR Art. 16). A non-EU seller with no EU legal entity, no EU-established importer of record, and no responsible person therefore needs to appoint one before listing.
The obligation is regime-specific. Under GPSR Art. 16 an EU-established importer can satisfy the responsible-person duty, but under MDR Art. 11 a medical-device manufacturer outside the EU must designate a sole authorised representative — an importer cannot substitute for it. For products using an EU fulfilment service with no importer, Reg (EU) 2019/1020 Art. 4 makes the fulfilment service provider the responsible person by default, and most providers decline that role, leaving the seller exposed.
Sources: Regulation (EU) 2023/988 (GPSR) Art. 16 — EUR-Lex (applies 13 Dec 2024) · Regulation (EU) 2017/745 (MDR) Art. 11 — EUR-Lex · Regulation (EU) 2019/1020 Art. 4 — EUR-Lex
Last updated 2026-08-12Regulatory citations verified 2026-08-12 against EUR-Lex consolidated texts (GPSR, MDR, Reg 2019/1020, RoHS)
EU Authorized Representative — frequent questions
Who needs an EU Authorized Representative?
A manufacturer or seller established outside the EU/EEA that places products on the EU market generally needs an EU-established responsible person. For products in scope of the General Product Safety Regulation (EU) 2023/988 that is the economic operator under Art. 16; for medical devices it is the sole authorised representative under MDR Art. 11; for products covered by Union harmonisation legislation it is the operator identified under Reg (EU) 2019/1020 Art. 4. If you already have an EU legal entity or an EU-established importer of record, the obligation may be covered without a separate AR — except for medical devices, where a sole AR is always required.
What changed on 13 December 2024?
The General Product Safety Regulation (EU) 2023/988 started to apply on 13 December 2024, replacing the old General Product Safety Directive. Its Art. 16 means a consumer product may not be placed on the EU market unless an economic operator established in the Union is responsible for it — so non-EU sellers without an EU presence must appoint a responsible person. This is why many marketplaces began requiring a responsible-person address on listings during 2024–2025.
Can my EU importer act as the responsible person instead of an AR?
Often, yes — for GPSR (Art. 16) and for products under Reg (EU) 2019/1020 (Art. 4), an EU-established importer of record can satisfy the responsible-person duty. The important exception is medical devices: MDR Art. 11 requires a non-EU manufacturer to designate a sole authorised representative, and an importer cannot substitute for it. This tool flags that override automatically when you select a medical device or IVD category.
I use Amazon FBA / a 3PL in the EU — does that cover me?
Not by default. Under Reg (EU) 2019/1020 Art. 4(2)(d), if no manufacturer, authorised representative or importer is established in the EU, a fulfilment service provider that handles the goods becomes the responsible person. In practice most fulfilment providers decline that role — Amazon ended its own Responsible Person service in 2024 — so relying on FBA or a 3PL to be your responsible person is a known compliance gap. Appoint an AR in writing rather than assuming the fulfilment provider covers it.
How much does an EU Authorized Representative cost per year?
Most providers do not publish a price at all. Of the nine EEA-established providers in the table below, six quote per case; the three that publish a headline annual entry tier, checked on their own pages on 12 August 2026, are EAS at €199/year for one product type, Cert-Rep at €1,190/year up to 5,000 items, and 24hour-AR at €2,450/year for up to 20 products. Those three are not comparable like for like — each tiers on a different unit (product types, items, products) — which is also why this tool does not scale any figure by your SKU count. For medical devices, none of the MDR/IVDR providers listed publishes a price. Treat the published tiers as a floor for the simplest engagement and get a written quote.
Is the responsible person the same as the Cosmetics Responsible Person?
No. Cosmetic products have a separate Responsible Person under Regulation (EC) 1223/2009, with its own product-information-file and safety-assessment duties that general AR services do not cover. If you sell cosmetics, treat that as a distinct appointment; this tool surfaces a note when a cosmetics category is selected and filters to providers that offer the cosmetics RP role.
Is this tool legal advice or a compliance certificate?
No. It is a deterministic triage estimator that maps your inputs to the EU regimes most likely in scope, citing the EUR-Lex source for each. It does not classify your specific product, draft any documentation, or certify compliance. It carries two separate verification dates — one for the regulatory citations, one for provider pricing — and when the pricing date lapses the prices are hidden rather than shown stale. Use the result to brief a qualified EU compliance adviser, and verify against the live regulation before placing goods on the market.
This site provides general information about Regulation (EU) 2023/988 GPSR Art 15-17 + Regulation (EU) 2017/745 MDR Art 11. It is not legal advice and does not create a professional relationship. We are not lawyers. For decisions affecting your business, consult a qualified professional in your jurisdiction. Information may be outdated; verify against official sources. Last updated: 2026-08-12.