ProductIP Authorised Representative Services [translations pending]

Placing products on the EU and or the UK market requires a local entity that can take care of questions asked by market surveillance authorities. 

If a product is not marked with the address information of a local entity, authorities will decide who is responsible for product compliance. For example, it could be your customer, the shop selling the product, or the fulfilment service provider you use to sell products directly to consumers. 

Most likely, neither would like to be placed in that role. Especially fulfilment service providers do not want to become responsible for product compliance and push sellers to find a solution. Setting up your local entity is a solution. However, it takes time and can prove to be costly. Note that a simple “PO Box” firm is not enough!

Luckily there is also an efficient alternative; assign ProductIP to act as your European and or UK Authorised Representative. 

How Smart Sellers maintain access to EU and/or UK market

Europe, per EU Regulation 2019/1020 applicable from July 16, 2021, and the UK in the post-Brexit situation, both do require companies to provide a local person or local entity responsible for product compliance information. One established inside the EU or the UK, that takes care of the communication with the market surveillance authorities. The address of the person or entity needs to be on the product label, on the packaging, manual, as well as on conformity declarations. This is essential to keep access to the market. Failing to do so is a formal non-conformity. 
Pressure to comply is mainly coming from your customers, retailers, importers and fulfilment service providers such as Amazon, eBay, AliExpress, Wish, Rakuten and many others. Why? Because in the legislation they will be held responsible for product compliance of all products that do not comply with this local entity requirement. They acknowledged their responsibilities in signing a Safety Pledge with the EU Commission.

There is a solution to secure keeping access to the market. One that ensures you keep access to the market and at the same time takes the pressure away from your customer or fulfilment service provider. One that also can take care of the communication with authorities. One that is instantly available and does not require you to go to the stressful and costly progress of registering and maintaining a local entity: ProductIP Authorised Representative (AR) Services.

ProductIP as your Authorised Representative

  • Confidential. ProductIP is neutral in the market and not involved in the trade of goods
  • Competent. ProductIP is expert in non-food consumer goods compliance legislation
  • Informed. ProductIP’s web-based solution ensures you keep track of regulatory changes
  • Compliant. ProductIP technical files ensure that:
    • correct Declarations of Conformity, CE and UK CA, declarations are being generated fast and correct
    • compliance information is stored
    • readily available for 10 years as is legally required in the EU and UK.
  • Efficient. ProductIP’s built-in Public Pages function enables you to provide consumer access to essential information via a unique URL accessible via a QR-Code

Advantages of using an AR

  • Set up and maintain a legal entity in the EU and/or the UK
  • Share confidential information with a commercial partner, distributor or agent
  • Modify / Change addresses / labels / manuals whenever distributors or agents change

Your distributors and agents can then focus on sales of products carrying your brand. ProductIP focuses on you, your products and requirements. ProductIP takes care of your interests. We offer stress-free product compliance.

Your legal options

European CE Marking Directives, and UK UKCA Marking Regulations, place the responsibility for compliance on the manufacturer of the product concerned. Even where the manufacturer is located outside the European Union or the UK, and therefore out of legal reaches of the EU or UK enforcement authorities, the manufacturer has certain obligations (e.g., quality control), which they cannot assign to other parties. The EU considers products underway to consumers as “being made available” and therefore they need to comply with all the requirements.

Moreover, in cases where the manufacturer is not based in the EU or the UK, legal responsibility for compliance with the directives lies with the entity responsible for selling the goods within the EU or UK, unless the manufacturer has appointed an Authorised Representative. The manufacturer can then assume his responsibility and give a mandate to ProductIP as an Authorised Representative to represent the manufacturer towards authorities.

Authorised Representatives or not?

The need for, and obligations of, Authorised Representatives are much misunderstood. All CE marking directives (in EU), and UKCA Marking Regulations (in UK) place responsibility for compliance on the manufacturer of the product concerned. These are the three options:

  1. Manufacturer / Brand-owner inside the EU / EFTA, or UK:
    • The brand name or registered trademark are on packaging, label, or other artwork
  1. Manufacturer / Brand-owner is outside the EU / EFTA or UK, imported by others
    • The brand name or registered trademark are on packaging, label, other artwork
    • ‘Manufactured by’: address information is that of the non-EU/non-UK brand owner
    • Additionally, ‘imported by’: name and address information are those of the EU/UK importer
  1. Manufacturer / Brand-owner / Seller is outside the EU / EFTA or UK, delivering products to consumers via Fulfilment Service Providers or via Drop-Shipping
    • The brand name or registered trademark are on packaging, label, other artwork.
    • Address information of the non-EU/non-UK brand owner is recommended.
    • ‘Manufactured by’: address information is that of ProductIP as Authorised Representative of the brand owner.
    • (Optional) Use the unique ProductIP generated QR-code on shipping documents and or  packaging to demonstrate that you comply with new rules and provide direct access for customs and the user/consumer to the essential compliance documentation. 

Option 3 is the ideal option for Sellers shipping to the end user via online platforms, regular import and trading channels or directly to consumers.

Note: The ProductIP Authorized Representative service is also available for brand owners already located within the EU / EFTA or UK. The benefits regarding info on labels, etc. are identical.

The local entity requirement applies also for EU companies selling in the UK, and for UK companies selling in the EU. Northern Ireland continues to follow the European Framework.

What is covered?

If the manufacturer is not based in the EU / EFTA, or not based in UK then legislation allows that their ‘Authorized Representative’ takes care of certain duties related to product compliance. Some call it “Responsible Person” but that is another obligation connected to specific product groups such as cosmetics and medical devices. ProductIP is not a Responsible Person as such. Note that this term is often misused in the market causing a lot of confusion.

The scope of the regulation EU 2019/1020 is limited to harmonised goods, resulting in application of CE marking. However, Germany extended the scope when transferring it into national law (ProdSG). In Germany it now also covers non-harmonised goods. Given the fact that the German market plays a significant role in the world of e-commerce this will have impact on the total market.

For the UK market it is relevant for all non-food products or as the UK legislation calls it: manufactured goods, including products that do not need to carry a CE marking.

The ProductIP Authorised Representative Service includes:

  • Keeping the technical documentation and any required EU or UKCA Declaration of Conformity at the disposal of national surveillance authorities and cooperate with them at their request
  • Upon a reasoned request from a competent national authority, provide that authority with all the information and documentation necessary to demonstrate the compliance of a product
  • Cooperate with the competent national authorities, at their request, on any action taken to eliminate the risk posed by products covered by the mandate
  • Immediate notification of product incidents based on timely information received from you as our customer
  • Per your instructions share information with commercial partners via the ProductIP platform (B2B) *
  • Per your instruction share information via URL and QR code (B2C) *
  • Collecting complaint information as provided by users/customers and forward to you as our customer

Additionally, ProductIP may arrange (through a third party) for you to deal with: *

  • Obligations following from nationally organised legislation such as WEEE, Battery Directive, Packaging Directive, Private Copying Legislation, mandatory registrations related to cosmetics, energy labelling.
  • Contracts and testing with testing and inspection organizations.
  • Contracts with insurance companies; we advise companies to consider taking out a product liability insurance coverage that covers the EU, EFTA and/or UK and other countries in the mandate for the Authorized Representative)

* Additional charges will be applicable

ProductIP holds no liability for any damages that occur from placing the products on the market. ProductIP holds no liability for any damages that occur from claims regarding patents and technology licenses.
Besides the annual fee to maintain your authorized representation we will provide you with a specified monthly financial statement for hours and expenses that occurred. Next to the annual fee, we charge you a one-time initial payment for 8 hours. We will ask upfront approval for events for which we expect the hours involved to exceed the initial payment. Mandatory usage of the ProductIP platform and creation of files are not included in this fee.


What do we expect from you as a responsible Manufacturer/Seller?

We need you to

  • Provide ProductIP with a clear mandate on what is included in the tasks and responsibilities of the Authorized Representative
  • Indemnify ProductIP from any product liability and consequential claims and damages
  • Place technical documentation in our trust via the ProductIP platform to ensure compliance with the availability requirements of the authorities
  • to have systems in place that ensure that compliance is maintained during mass production
  • Immediately notify us of product incidents
  • Fully cooperate with requests from competent national authorities

For this purpose we conclude with you an EU or UK Authorised Representative Service Agreement. It just takes three steps. 

Click here to download the agreement text for EU Authorized Representative

Click here to download the agreement text for UK Authorized Representative

STEP 1. Create your account in ProductIP, you can digitally sign the Authorized Representative Agreement. It is a clear step-by-step process.

STEP 2. We will raise an invoice and e-mail that as PDF. Settle the related annual fee to activate the agreement.

* You will be invoiced in Euro’s from the Netherlands. Or in HK$ or US$ from Hong Kong.

STEP 3. Buy credits so you can start making technical files in ProductIP. Adapt your artwork with the new address information and support compliance via files in your ProductIP account*

* Technical files need to be created in ProductIP. For this service several support and pricing models exist. click here for the ProductIP Service Overview

Welcome to stress-free product compliance. Continue increasing your business.

Are your products in our scope?

The ProductIP Authorised Representative services are possible for non-food products (manufactured goods) that are under the scope of one or more of the following EU directives/regulations and their UK equivalents

General Product Safety Directive (General Merchandise) General Product Safety Regulations (General Merchandise)
Framework for Food Contact Materials The Materials and Articles in Contact with Food Regulations
Low Voltage Directive The Electrical Equipment (Safety) Regulations
Electromagnetic Compatibility Directive Electromagnetic Compatibility Regulations
Personal Protective Equipment Directive Personal Protective Equipment Regulations
Toys Directive Toys Regulations
RED Directive Radio Equipment Regulations
Machinery Directive Supply of Machinery Regulations
Construction Products Regulation Construction Products Regulations
RoHS (not including WEEE services!) RoHS Regulations
Cosmetics Regulation (Not Responsible Person services!) Cosmetics Regulations 
Detergents Regulation Detergents Regulations
Pressure Equipment Directive Pressure Equipment Regulations
Outdoor Noise Directive Outdoor Noise Regulations
Automotive regulations The Road Vehicles Approval Regulations
Measuring Instruments Directive Measuring Instruments Regulations
Non-automatic Weighing Instruments Directive Non-automatic Weighing Instruments Directive
Aerosol Dispensers Directive Aerosol Dispensers Regulations
Medical Device Regulation (ONLY class I, non-sterile) Medical Devices Regulations (ONLY class I, non-sterile)


And various other applicable regulations as generated from the ProductIP regulatory database. Involvement of Notified Bodies (EU) or Assessment Bodies (UK) may be required in order to comply with the essential requirements. ProductIP does not provide Responsible Person services. ProductIP does not provide a post-market surveillance system. Excluded are medicines, products that are also covered by the Medical (Sterile, Class 2 and 3) and/or Pyrotechnic Products and/or ATEX Directives and/or Annex IV of the Machinery Directive and living organisms, and their UK equivalents.