Why an Authorised Representative should be more than an EU address
The role of an AR increasingly requires substance, expertise and the ability to act when it matters.
Authorised Representative services have traditionally been presented by some providers as a relatively simple proposition: sign a mandate, receive an EU address and start selling.
European regulatory developments increasingly point in a different direction.
The European Commission’s GPSR guidance makes clear that an Authorised Representative should not merely have the formal authority to represent a manufacturer. According to the guidance, the representative should also have sufficient practical and administrative capacity to perform its obligations and the necessary legal and factual knowledge.
That is an important distinction.
An AR may need to understand technical documentation, respond to requests from market surveillance authorities and perform the tasks defined in its mandate. Under the Market Surveillance Regulation, the authorised representative must perform the tasks assigned to it and be able to provide the mandate to authorities upon request.
At the same time, the Commission is reviewing the wider EU framework governing product compliance and market surveillance. The planned European Product Act is intended to update both the New Legislative Framework and the Market Surveillance Regulation.
Against that background, EurHub believes manufacturers should look beyond price and speed when choosing an AR.
A provider promising to become your Authorised Representative within 24 hours may be able to process a signature quickly. But the more relevant question is whether that provider has taken the time to understand your company, your products, the applicable legislation and the documentation it may later be expected to deal with.
EurHub deliberately takes a different approach.
We start with onboarding. We want to understand the manufacturer and the products we represent. Technical documentation is submitted through our client portal and reviewed within the agreed scope. Where more specialist knowledge is needed, we can draw on a network of professionals with expertise in product safety, regulatory compliance, technical matters and related areas.
Our founder’s legal and regulatory background also means that questions are not automatically passed from an account manager to someone else when they become more complicated.
For EurHub, authorised representation is therefore not an address-rental service.
It is representation backed by expertise, experience and hands-on support.
And as scrutiny of economic operators increases, we expect the substance behind an AR appointment to become increasingly important.
