
Product Liability Directive 2026: your EU representative
Product Liability Directive: your Authorized Representative becomes liable for products placed on the EU market after 9 December 2026. What to check now.
If you manufacture outside the EU, most CE-marked products need an economic operator established in the EU before they can be sold there. We take this role as your Authorized Representative by written mandate, with our name and address on your products.

You want to sell in the EU directly to customers, through distributors or on marketplaces. Buyers, platforms and authorities ask who your economic operator in the EU is, and your labels need a name and address there.
Article 4 of Regulation (EU) 2019/1020 sets the basic rule for most CE-marked products.
Products under the acts in Article 4(5), such as electrical and radio equipment, machinery, toys and PPE, need an economic operator established in the EU.
The role can be an EU manufacturer, your EU importer, an Authorized Representative with a written mandate or, as a fallback, a fulfillment service provider.
The operator's name and postal address go on the product, its packaging, the parcel or an accompanying document.
Design, manufacture and the technical documentation remain your tasks as manufacturer. As a rule, they cannot be delegated to a representative.
Product Compliance & DocumentationWe act under a written mandate for the tasks it names, while responsibility for your product, its design, conformity assessment and Declaration of Conformity stays with you.
Talk to our teamAppointed by written mandate within 24 to 48 hours once your product details and documents are complete.
For each product and sales channel, we clarify who acts as your EU economic operator: your importer, a fulfillment provider or us.
Our name and address for your product, packaging or accompanying document and, where your act provides for it, your Declaration of Conformity.
We keep your Declaration of Conformity and technical documentation available to market surveillance authorities for 10 years.
We answer authority requests, provide your documents and cooperate on corrective action, always in close contact with you.
Once a year we review your Declaration of Conformity and technical file and tell you what needs updating.
01
You tell us about your products, markets and sales channels. We name the rules and the EU role you need.
02
You send your documents. We review them, and you sign the written mandate that defines our tasks.
03
Once your documents are complete, we confirm the appointment within 24 to 48 hours and send our details for labels.
04
We answer authority requests, keep your documents available and review your file every year.
Not necessarily. Your EU importer can be the economic operator required by Article 4 of Regulation (EU) 2019/1020 for the products it places on the market. A representative helps where you ship directly to customers, sell through several importers or want one contact for authorities.
Products under the acts listed in Article 4(5) of Regulation (EU) 2019/1020, including electrical equipment, EMC, radio equipment, RoHS, machinery, toys, PPE, gas appliances, pressure equipment, construction products and batteries. Most consumer products without CE marking need one under Article 16 of the GPSR.
Only if the applicable act allows it and the written mandate names this task. The declaration is still issued under the manufacturer's sole responsibility, and drawing up the technical documentation stays with the manufacturer unless the act provides otherwise (Blue Guide, section 3.2).
Usually within 24 to 48 hours once we have your product details and complete documents.
It can. Under the Windsor Framework, EU product rules apply in Northern Ireland, and operators that must be established in the EU may also be established there (Blue Guide, section 2.9.6). A company established only in Great Britain cannot take the role.

Product Liability Directive: your Authorized Representative becomes liable for products placed on the EU market after 9 December 2026. What to check now.

EU Authorized Representative vs importer: who places your goods on the market, whose name goes on the label and who is liable from December 2026.

What an EU Authorized Representative does under GPSR and Regulation (EU) 2019/1020, what is at risk without one and why a passive provider is not enough.

We look at your products and sales channels and tell you which EU role you need and which documents we need from you.
Tell us what you manufacture and where you want to sell. We identify the requirements for EU and UK market access and come back to you with the next steps.