In This Article
- Non-EU Amazon sellers often require an EU Authorised Representative to comply with EU regulations.
- Post-Brexit, UK-based sellers are treated as non-EU businesses and must follow the same requirements.
- Amazon has significantly tightened enforcement—compliance is critical to avoid suspension.
- Only products regulated under EU legislation require a representative, but strategic advantage comes with having one.
- Choose a qualified representative contractually and list their details as required by law.
- Common pitfalls include failing to appoint one or improperly showcasing representative details.
- Follow best practices to avoid regulatory breaches, protect your brand, and win consumer trust.
What Is an EU Authorised Representative?
Definition and Legal Basis
An EU Authorised Representative is a natural or legal person located within the European Union who has been explicitly appointed by a non-EU manufacturer to act on their behalf regarding specific tasks outlined in EU directives and regulations. For vendors selling goods into the EU market via platforms like Amazon, having an EU Authorised Representative is often not just a wise choice—it is a legal necessity. They act as your in-market contact for all compliance and regulatory issues, especially concerning product safety and documentation requirements. Under frameworks such as the CE marking, the EU Authorised Representative holds responsibilities like keeping declarations of conformity and ensuring the availability of technical files for inspection by market surveillance authorities.
When Do Amazon Sellers Need an EU Representative?
Mandatory Scenarios for Non-EU Sellers
If you’re a manufacturer, importer, or private label seller based in the US or UK and selling physical products via Amazon into EU countries, you’ll likely need an EU Authorised Representative. EU regulations such as the General Product Safety Directive, the Low Voltage Directive, or the Medical Devices Regulation mandate this intermediary for many product types. Amazon itself is now more stringent about seller compliance, aligning its policies with EU laws. As a result, you must provide evidence of regulatory compliance, including proof of an appointed EU Authorised Representative, to prevent account suspension or product delisting.
“Non-EU sellers must designate an EU Authorised Representative when mandated by EU regulations or risk losing access to Amazon’s European marketplaces.”
Understanding UK vs. EU Compliance Rules
The divergence between the UK and EU regulatory frameworks since Brexit has introduced additional complexity for Amazon sellers. While both jurisdictions enforce high safety and compliance standards, the UK now operates under its own regime, including use of the UKCA (UK Conformity Assessed) mark. By contrast, within the EU, CE marking remains the standard. A key distinction is that UK businesses selling into the EU must now appoint an EU Authorised Representative to meet EU product compliance obligations—something that wasn’t required prior to Brexit. Confusion often arises among sellers who presume UK compliance extends to the EU, which it no longer does.
In essence, UK-based businesses are treated the same as US-based ones in the eyes of the EU regulatory bodies. Therefore, if your company is situated in the UK and you sell goods to EU consumers via Amazon, you are required to appoint an EU Authorised Representative. Failing to do so can result in non-compliance and marketplace penalties, reinforcing the need to reassess international expansion strategies post-Brexit.
How Amazon Enforces EU Regulations on Sellers
Amazon, as a dominant marketplace operator, has evolved into an active compliance enforcer. It closely monitors whether products listed comply with European legislation, including those requiring an EU Authorised Representative. Sellers will find that, in many product categories, Amazon requires documentation uploads before approving listings. This may include the EU Declaration of Conformity, test reports, and EU Authorised Representative contact details.
Sellers who attempt to bypass these requirements can quickly find themselves flagged in Amazon’s system, leading to delisting or restrictions on product visibility in EU locales. Amazon’s compliance team is particularly watchful in regulated spaces like toys, electronics, cosmetics, and medical devices. Ensuring that you meet all regulatory benchmarks not only keeps your Amazon account secure but also builds consumer trust across borders.
Do I Need an EU Authorised Representative for All Amazon Products?
Not every Amazon product sold into the EU legally requires an EU Authorised Representative, but many do. Products governed by EU harmonisation legislation fall under this obligation. These include electronics (subject to the Low Voltage or EMC Directives), toys (Toy Safety Directive), cosmetics (EU Cosmetics Regulation), and medical devices (MDR). It’s crucial to analyse each product category against the applicable EU legislation before assuming your listing is compliant.
Additionally, product liability risks increase when proper compliance procedures are skipped. By appointing an EU Authorised Representative, you mitigate legal exposure and signal to your buyers and Amazon that you are a legitimate and trustworthy seller. Even unregulated products can sometimes benefit from having an EU contact for returns, documentation, and support—particularly if selling through Fulfilment by Amazon (FBA).
How to Appoint an EU Authorised Representative
Appointing the right EU Authorised Representative involves several formal steps. Start by identifying a reputable firm or professional located within the European Union. This individual or company must possess the expertise to handle your product’s compliance documentation, liaise with EU authorities, and assist with regulatory audits. Your contract should clearly delineate roles and responsibilities to ensure compliance alignment.
Once selected, you’ll typically issue a formal “Mandate Letter” or “Delegation Agreement” to establish the legal authority of the representative. This document should be retained with your product’s technical file and cited on labels where necessary. Sellers must also list the EU Authorised Representative’s name and address on the product or packaging—as required by specific EU Directives. For step-by-step guidance on this, refer to our compliance toolkit here: Learn more about EU Compliance for Amazon Sellers.
Top Benefits of Having an EU Authorised Representative
There are numerous strategic advantages to appointing a qualified EU Authorised Representative. First and foremost, it ensures legal compliance and protects your Amazon operations from enforcement actions and penalties. Sellers also gain access to niche legal support within the EU, improving readiness during audits or investigations. Moreover, having a reliable representative can simplify communication with EU customers, distributors, and customs officials.
Additionally, your EU Authorised Representative serves as a durable point of contact even when you’re unavailable due to time zone differences or operational constraints. This reduces friction in fulfilment and issue resolution, ensuring customers continue to receive reliable service. With Amazon tightening regulatory enforcement, investing in a trusted representative has become a competitive differentiator. To learn how to choose the best representative, see our deep-dive here: Read a related article.
Common Compliance Mistakes to Avoid (Case Studies)
Many Amazon sellers stumble over familiar tripwires when entering the EU marketplace. One such common error is assuming that an importer or logistics provider can automatically serve as the EU Authorised Representative. In practice, these roles are distinct, and failing to appoint a formal representative can lead to rejected shipments or even fines. Let’s consider a real scenario: A US-based electronics seller launched in Germany via Amazon FBA without an EU Authorised Representative. Despite strong sales figures, several product complaints led to a market surveillance inspection. The seller lacked the proper documentation and local representative, triggering a product recall and account freeze.
Another prevalent mistake is incorrectly labelling the EU Authorised Representative’s details. EU law often requires that this information be visible on packaging or within accompanying documentation. Omissions or incorrect data may prompt customs to seize the shipment. Learn more about regulatory pitfalls here: Comprehensive overview of Amazon’s GPSR compliance rules.
Best Practices for International Amazon Sellers
Success in the EU Amazon landscape relies on planning, documentation, and proactive compliance. Start by mapping each product you offer against relevant EU legislation. Identify if it falls within a regulated category, and if so, outline the exact documentation required. If an EU Authorised Representative is mandated, select one before product launch—not afterwards. Be sure to establish a contract outlining their responsibilities and include their information on your packaging where applicable.
Ongoing success also means remaining vigilant. Monitor EU regulatory updates affecting your product categories and maintain open communication with your representative. Additionally, always respond promptly to Amazon’s compliance queries to avoid disruptions. Document retention is another crucial element; technical files should be updated annually or after any design changes. Finally, always prioritise user safety and transparency, both of which reinforce buyer confidence and brand integrity.
Frequently Asked Questions About Amazon EU Compliance
Q: What happens if I don’t have an EU Authorised Representative?
A: Amazon may delist your products, and EU authorities may impose fines or stop your shipments at the border.
Q: Can my freight forwarder act as an EU Authorised Representative?
A: Not unless formally authorised and listed in compliance documentation. The roles are distinct and legally defined.
Q: Is a separate representative needed for each EU country?
A: No. One legally appointed EU Authorised Representative can serve for the entire EU market.
Q: Do digital products or services require an EU Authorised Representative?
A: No. This requirement typically applies only to physical goods under specific directives or regulations.
Conclusion: Selling Into the EU Made Simple
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Great guide on do-i-need-an-eu-authorised-representative-to-sell-on-amazon-from-the-usa-or-uk-interactive – Community Feedback
Can I sell goods on UK Amazon as a registered USA LLC?
Yes, you can sell on Amazon UK as a registered USA LLC. You may need to register a UK company for some activities, but Amazon generally allows international sellers. Compliance with local regulations, including appointing an EU authorised representative if selling into the EU, is essential.
Can you sell on Amazon USA from the UK?
Yes, Amazon allows sellers from the UK to sell on Amazon USA and vice versa. You can use Amazon’s global selling platform to expand internationally, as long as you follow all required compliance and tax regulations.
Can a non-US citizen sell on Amazon?
Yes, non-US citizens can sell on Amazon, but you must set up a business account in your country of operation. You may need professional assistance to ensure compliance and proper business registration.
Can I sell on Amazon as an individual in the UK?
Yes, individuals can sell on Amazon UK. Amazon offers both individual and professional selling plans. Ensure you meet the necessary compliance and documentation requirements for your products.
