Authorized Representative mandate: what to put in writing
9 min read
Authorized Representative mandate: the minimum tasks per EU act, what you cannot delegate, the copy for authorities and how to end or switch it.
You make products outside the EU and have an EU Authorized Representative, or you are about to appoint one. The written authorized representative mandate decides what your representative may do, authorities can ask to see it, and you rely on it when you change providers. Here is what goes in, what stays out, what other laws add and how to switch without a gap.
What an authorized representative mandate is, and who reads it
An EU Authorized Representative is established in the EU and holds a written mandate from a manufacturer to act on its behalf for specified tasks (Article 3(12) of Regulation (EU) 2019/1020 (opens in a new tab); Article 3(9) of the General Product Safety Regulation (EU) 2023/988 (opens in a new tab), GPSR). The Commission's Blue Guide 2022 (opens in a new tab) wants the delegation in writing, "in particular to define the contents and limits of the representative's tasks" (section 3.2).
Authorities can ask your representative for a copy of the mandate (Article 10(2) GPSR); for CE products under Article 4 of Regulation (EU) 2019/1020, in a Union language the authority determines (Article 5(2); see answering a market surveillance authority).
The minimum tasks the mandate must allow
Consumer products without CE legislation follow the GPSR. CE products follow their sector act, mostly built on Decision No 768/2008/EC (opens in a new tab) (Annex I, Article R3); the GPSR's rules on representatives do not apply to them (Article 2(1)(b) GPSR).
| Products | The mandate must allow at least | Never part of the mandate | Basis |
|---|---|---|---|
| Consumer products without CE legislation | Documents showing safety on a reasoned request; telling you of a suspected dangerous product; Safety Business Gateway notices (the EU reporting portal) on risk measures you have not reported; cooperation | No exclusion clause; the safety duties stay yours | Art. 10(2) GPSR |
| CE products, for example under Directive 2014/35/EU | Keep the EU Declaration of Conformity (DoC) and technical documentation for 10 years; documents on a reasoned request; cooperation | Design and manufacture; drawing up the technical documentation | Art. 7 Directive 2014/35/EU |
| Machinery, from 20 January 2027 | The same, for at least 10 years | The same | Art. 12 Regulation (EU) 2023/1230 |
| Toys, from 1 August 2030 | Technical documentation and digital product passport for 10 years; documents on a reasoned request; cooperation; Safety Business Gateway notices; for makers outside the EU, the Article 4(3) tasks | The same | Art. 8 Regulation (EU) 2025/2509 |
For your representative to be the EU economic operator that Article 4 of Regulation (EU) 2019/1020 requires for most CE products (for GPSR products, your Responsible Person, Article 16(1) GPSR), the mandate must include all tasks of Article 4(3), such as informing authorities of risks and making sure corrective action is taken (Articles 4(2)(c), 5(1)). The Commission's Article 4 guidelines (opens in a new tab) tell manufacturers to review older sector mandates for this (section 4.3). Toys in detail: the toy mandate.
What stays with you, and what the mandate may add
The delegable tasks are administrative: a representative cannot modify the product on its own initiative (Blue Guide, section 3.2). The exclusions in the table follow Article R3(1) of Decision No 768/2008/EC, taken over for example in Article 7(1) of Directive 2014/35/EU (opens in a new tab). Under the GPSR, risk analysis and technical documentation remain your duty (Article 9(2) GPSR).
A mandate may go further (the Commission's GPSR guidelines (opens in a new tab), section 3.1.2). Depending on the act, the Blue Guide names affixing the CE marking, drawing up and signing the DoC and acting as the Article 4 economic operator (section 3.2; who signs the EU Declaration of Conformity).
Keep stock and shipping out of it: a representative that supplies products to distributors or consumers in the EU becomes the importer (Blue Guide, section 2.5; Authorized Representative or importer).
Seven clauses to settle before you sign
Beyond the legal minimum, settle these points (fees go in a separate agreement, as authorities may see the mandate):
- Parties: the representative's name, postal and electronic address exactly as on labels and listings.
- Products: models or types covered, and how new ones are added.
- Legal bases and role: each applicable act, and whether the representative is your EU economic operator.
- Tasks: the minimum from the table, written out; options such as signing the DoC; for a Responsible Person, the regular checks of Article 16(2) GPSR.
- Documents: where the technical documentation is kept, how fast you deliver it, in which languages.
- Reports: who files Safety Business Gateway notices, including accidents your representative learns of (Article 20(4) GPSR); see post-market duties.
- Term and exit: notice period, end date, document handover, forwarding of requests about units already sold.
Duties other laws attach to your representative
Some laws attach duties to the Authorized Representative role itself:
| Law | What it assigns to the representative | Applies to |
|---|---|---|
| Product Liability Directive (EU) 2024/2853 | Liability for defective products of a manufacturer outside the EU, alongside any importer (Art. 8(1)(c)(ii)), not limitable by contract towards the injured person (Art. 15) | Products placed on the market or put into service after 9 December 2026, through national law (Art. 2(1)) |
| Right to Repair Directive (EU) 2024/1799 | Repair on the consumer's request for goods covered by Annex II, such as washing machines, refrigerators, smartphones and tablets, if the manufacturer is outside the EU; may be sub-contracted (Art. 5(1), (3)) | National rules, to be applied from 31 July 2026 (Art. 22(1)) |
For repair, check national law with your representative: when the Commission opened infringement procedures on 25 September 2026, 18 member states had not notified complete transposition (European Commission (opens in a new tab)), and the directive takes its definition of authorized representative from the Ecodesign Regulation (EU) 2024/1781, which refers to a mandate for obligations under that regulation (Article 2, point 6). Liability in detail: liability and your representative. Producer responsibility roles for packaging, electrical waste and batteries are separate national mandates (electrical waste in Germany).
Ending or switching the mandate without a gap
Regulation (EU) 2019/1020 and the GPSR set no procedure for ending a mandate; the Article 4 guidelines only note that a representative may try to end the relationship if the manufacturer stops responding (section 3).
Products under Article 4 and GPSR products may be placed on the market only while an EU operator holds the role (Article 4(1), Article 16(1) GPSR); without a representative, direct shipments to EU end users may not be offered (Article 4 guidelines, Box 1, step 6; no EU economic operator).
Medical device law lists what a switch agreement must cover: end and start dates, how long the old name may still appear, document transfer and the forwarding of complaints (Article 12 of Regulation (EU) 2017/745 (opens in a new tab)), a good model for other products too.
Labels follow the unit. Units placed on the market from the switch date carry the new representative's details (Article 4(4) of Regulation (EU) 2019/1020, Article 16(3) GPSR). Stock released for free circulation in an EU fulfillment warehouse is already on the market (Blue Guide, sections 2.3 and 2.4), and neither regulation says whether it must be relabeled: agree that your former representative forwards requests about it for a set period.
Update every online offer on the switch date (Article 19(b) GPSR). Where your DoC names the representative, issue a new version for units placed on the market afterwards (Blue Guide, section 4.4).
Example: an Asian tablet maker switches representative
An Asian maker of Wi-Fi tablets sells through its own shop and an EU fulfillment warehouse. Tablets are radio equipment under Article 4 of Regulation (EU) 2019/1020 and covered by Annex II of the repair directive. It switches representative on 1 March 2027:
| Item | Arrangement | Basis |
|---|---|---|
| Mandates | New mandate with the radio equipment and Article 4(3) tasks from 1 March; old mandate ends 28 February | Art. 11 Directive 2014/53/EU; Art. 5(1) Regulation (EU) 2019/1020 |
| Boxes and older units | New details on units placed on the market from 1 March; for stock released earlier, the old representative forwards requests for an agreed period | Art. 4(4) Regulation (EU) 2019/1020; handover clause modeled on Art. 12 Regulation (EU) 2017/745 |
| Repair requests | Both contracts name who receives them and which repair service performs them | Art. 5(3) Directive (EU) 2024/1799 |
Common mistakes with representative mandates
- A mandate without tasks. It leaves the contents and limits of the role open (Blue Guide, section 3.2).
- Copying only the sector minimum. Without the Article 4(3) tasks, your representative is not your EU economic operator (Article 5(1) of Regulation (EU) 2019/1020).
- Delegating the technical file. Under most CE acts, your representative may keep it but not draw it up (for example Article 7(1) of Directive 2014/35/EU).
- Ending before the successor starts. Direct shipments to EU end users then may not be offered (Article 4 guidelines, Box 1, step 6).
Conclusion: write the mandate for the day you need it
A good mandate names products, acts and tasks, leaves the manufacturer's duties with you and plans its own end. Review it when you add products or a new act applies, such as the Machinery Regulation from 20 January 2027.
Representa acts as your EU Authorized Representative by written mandate, within the agreed scope and mandate: our name and address for packaging and the Declaration of Conformity, your technical documentation kept for 10 years and authority inquiries handled. For consumer products, the mandate can also make us your GPSR Responsible Person. You remain the manufacturer.
Frequently asked questions
Does an EU Authorized Representative mandate have to be in writing?
Yes. EU law defines the Authorized Representative by its written mandate from the manufacturer (Article 3(12) of Regulation (EU) 2019/1020, Article 10(1) GPSR). The Blue Guide expects the mandate to set out the contents and limits of the representative's tasks explicitly.
Can my Authorized Representative draw up my technical documentation?
Not under the CE acts built on Decision No 768/2008/EC, such as the Low Voltage Directive (Article 7(1)) or, from 20 January 2027, the Machinery Regulation (Article 12(1)): drawing up the technical documentation is excluded from the mandate. Your representative keeps it available for authorities and signs the DoC only where the act and the mandate allow it.
Who can ask to see the mandate?
Market surveillance authorities. Your representative must provide a copy on request (Article 10(2) GPSR); for CE products covered by Article 4 of Regulation (EU) 2019/1020, in a Union language the authority determines (Article 5(2)).
What happens if my representative ends the mandate?
Products under Article 4 of Regulation (EU) 2019/1020 and GPSR products may only be placed on the market while an EU economic operator holds the role (Article 4(1), Article 16(1) GPSR). Without a successor, an importer or fulfillment service provider covers only its own units, and direct shipments to EU end users may not be offered.
Does the mandate of my EU representative also cover the UK?
Only Northern Ireland, where EU product rules apply and an Authorized Representative may be established in the EU or in Northern Ireland (Blue Guide 2022, section 2.9.6). EU product legislation no longer applies in Great Britain (section 2.9.5.2), which has its own rules.
