What an EU authorised representative is
The GPSR defines an authorised representative as a person or business “established within the Union who has received a written mandate from a manufacturer” to act for it on specified tasks (Article 3(9)). A seller that markets products under its own name or trade mark counts as their manufacturer (Article 3(8)), so this is the role a brand outside the EU can give to a business inside it.
The GPSR also uses a wider term. Article 16 is headed “Responsible person for products placed on the Union market”: a product covered by the GPSR may not be placed on the EU market unless a business established in the EU is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020. That business can be the manufacturer, if it is established in the EU, an importer, or an authorised representative with a written mandate. Only where none of those is established in the EU does a fulfilment service provider hold the role, for the products it handles (Regulation (EU) 2019/1020, Article 4(2)). An authorised representative is one of the businesses that can hold it.
The tasks are the same whoever holds the role: keep the EU declaration of conformity and the technical documentation available where the product's rules require them, give a market surveillance authority the information it asks for on a reasoned request, tell the authorities when there is reason to believe the product presents a risk, and cooperate on corrective action (Article 4(3)). Under the GPSR the business must also, where appropriate for the product's risks, regularly check the product against its technical documentation and its identification, contact and safety information, and show evidence of those checks on request (Article 16(2)).
The business's name and postal and electronic address go on the product, its packaging, the parcel or an accompanying document (Article 16(3)). Any online offer of a product whose manufacturer is outside the EU must show them too (Article 19(b)).
| Term | Where it comes from | What it means for a seller |
|---|---|---|
| Authorised representative | GPSR Article 3(9); Regulation (EU) 2019/1020 Article 4(2)(c) | A business in the EU you appoint by written mandate to act for you |
| Responsible person | GPSR Article 16 | Whichever business in the EU holds the role for your product: the manufacturer established in the EU, the importer, the authorised representative or, failing those, the fulfilment service provider |
| Responsible Person (cosmetics) | Regulation (EC) No 1223/2009 Article 4 | The person designated in the EU for a cosmetic product: for an imported cosmetic, the importer, or a person it designates by written mandate |
| Economic operator | GPSR Article 3(13) | The umbrella term: manufacturer, authorised representative, importer, distributor, fulfilment service provider and anyone else with obligations under the GPSR |
| UK responsible person | Statutory Instrument (SI) 2019/696, Schedule 34 (cosmetics in Great Britain) | For a cosmetic sold in Great Britain, a responsible person established in the UK: a UK manufacturer of a UK-made cosmetic, the importer, or a person either designates in writing |
Eldris sells the role as the EU & UK Responsible Person: EldrisAi OÜ, in Tallinn, Estonia, is named for your EU markets, and the UK appointment is held by EldrisAI. Eldris does not prepare your declarations of conformity or technical files: you or your test laboratory do.
Who must appoint one
It depends on where your business is established and what you sell. Online sales count: an offer is treated as making a product available in the EU when it is targeted at consumers in the EU (GPSR, Article 4).
| Your business and products | Selling in the EU | Selling in Great Britain |
|---|---|---|
| Outside the EU; consumer products covered by the GPSR | Yes. Your EU importer or an authorised representative you appoint must hold the role; only where neither exists does your fulfilment service provider hold it (GPSR Article 16(1); Regulation (EU) 2019/1020 Article 4(2)) | A UK representative is optional under the 2005 Regulations: the producer is the manufacturer's UK representative “if he has” one, otherwise the business in the UK that places the product on the market |
| Outside the EU; products under the acts listed in Regulation (EU) 2019/1020 Article 4(5) (in its original text, among others the toy, low-voltage electrical equipment, radio equipment, machinery and personal protective equipment rules) | Yes. Your EU importer or an authorised representative you appoint (Regulation (EU) 2019/1020 Article 4(1)-(2)) | Not covered on this page |
| Outside the EU; cosmetics | Yes. A Responsible Person designated in the EU (Regulation (EC) No 1223/2009 Article 4(1)); for imported cosmetics the importer holds it or designates one | Yes. A responsible person established in the UK; the importer holds it unless it designates someone else |
| In the EU; you make or import the products | No. As the manufacturer or importer established in the EU, you hold the role (Regulation (EU) 2019/1020 Article 4(2)) | Cosmetics: yes, a responsible person established in the UK (the importer, or a person it designates) |
| Manufacturer outside the EU; medical devices or in vitro diagnostic medical devices | A different authorised representative, under the Medical Devices Regulation and the In Vitro Diagnostic Medical Devices Regulation (see below) | Not covered on this page |
A business in the UK is outside the EU: for its EU sales, the rows for businesses outside the EU apply. Where the GPSR's rule does not apply because a product is covered by specific EU product legislation (GPSR Article 2(1)), Regulation (EU) 2019/1020 Article 4 sets the same requirement for the acts listed in its Article 4(5), and cosmetics have their own rule. Check which rules cover your product before you sell.
What it costs
With Eldris you pay £195 for each market you appoint us in, one-off, then one monthly plan for all your markets, priced by the number of products (SKUs). 5% off the market fees from 4 markets, 10% from 7, 15% from 10.
| Markets | Discount on the market fees | Market fees, one-off |
|---|---|---|
| 1 | None | £195 |
| 3 | None | £585 |
| 4 | 5% | £741 |
| 6 | 5% | £1,111.50 |
| 7 | 10% | £1,228.50 |
| 9 | 10% | £1,579.50 |
| 10 | 15% | £1,657.50 |
| 27, every EU member state | 15% | £4,475.25 |
| 28, every EU member state and the UK | 15% | £4,641 |
| Products (SKUs) | Price a month |
|---|---|
| Up to 20 SKUs | £19.95 |
| Up to 50 SKUs | £39.95 |
| Up to 250 SKUs | £99.95 |
| Up to 500 SKUs | £149.95 |
| Up to 1,000 SKUs | £195.95 |
| Up to 2,000 SKUs | £249.95 |
One market (Germany) with up to 20 SKUs: £195 once, then £19.95 a month, which is £434.40 in year one and £239.40 a year after. Germany, France, Italy and Spain with up to 50 SKUs: £741 once (5% off the market fees), then £39.95 a month, which is £1,220.40 in year one and £479.40 a year after.
The monthly plan keeps your appointment active: our address on your label and listings, replies to the authorities for you, and the portal with your certificates. Month to month; cancel any time. Your appointment does not produce the safety report (CPSR) or the product information file (PIF). Eldris prepares both as a separate service, £195 per formula. As your Responsible Person, Eldris can also notify your products on the CPNP (the EU cosmetic products notification portal): £99 per CPSR, chosen at checkout.
Year-one and three-year totals by SKU count and number of markets · Full pricing and what is included
