Authorised representatives under the CRA

A manufacturer may appoint a person established in the EU, by written mandate, to perform specified tasks on its behalf. The representative is a contact and documentation function, not a substitute manufacturer or an automatic confirmation of conformity.

Law

An authorised representative is a natural or legal person established in the Union that has received a written mandate from a manufacturer to act on its behalf for specified tasks. Appointment under Article 18 is optional, not a general CRA requirement for every non-EU manufacturer. Other applicable market-surveillance or product legislation may require an EU economic operator; assess that separately.

The mandate must allow the representative at least to:

keep the EU declaration of conformity and technical documentation available to market-surveillance authorities for at least ten years after placement or for the support period, whichever is longer;
on a reasoned request, provide an authority with all information and documentation necessary to demonstrate conformity;
cooperate at an authority’s request on action to eliminate risks posed by products covered by the mandate.

The representative performs only the tasks specified in the written mandate and must provide a copy of it to market-surveillance authorities on request.

Core manufacturer obligations under Article 13(1)–(11), Article 13(12), first subparagraph, and Article 13(14) cannot form part of the mandate. The manufacturer therefore retains responsibility in particular for conformity of design, development and production, risk assessment, component due diligence, vulnerability handling, the support period, update availability, drawing up technical documentation and keeping series production in conformity. Appointing a representative does not alter the manufacturer’s responsibility for the product.

Do not confuse these roles

Role	Meaning
Article 18 authorised representative	acts in the EU for the manufacturer only within the written mandate
Importer	places a non-EU manufacturer’s product on the Union market and has separate Article 19 duties
Distributor	makes a product available in the supply chain without affecting its properties
Notified body	independent third party performing an applicable conformity assessment
SRP “Assigned Representative”	an ENISA platform user/operational reporting role; the label alone does not create an Article 18 mandate

Guidance — mandate review

The written document should clearly state:

manufacturer and representative identity and address;
exact products, models, versions and territorial scope;
permitted tasks and expressly excluded non-delegable obligations;
documentation location, format, language, access and retention;
process for handling an authority request, validating it and meeting deadlines;
contacts, escalation and authority to cooperate on risk elimination;
access to updated records following product change and after the commercial relationship ends;
confidentiality, personal-data protection, cybersecurity and continuity;
start, termination, file handover and notification of representative changes.

Before signing

The representative is established in the EU and resourced for the tasks.
Product and version scope is unambiguous.
The mandate includes all three minimum Article 18(3) tasks.
It does not transfer duties excluded by Article 18(2).
The manufacturer can securely provide an up-to-date file on time.
Importer, representative, notified-body and SRP roles are not conflated.

Page sources: CRA Articles 3(15) and 18; Article 13; Annex VIII provisions allowing specified procedural tasks to be performed under mandate.