Recently, some France-based sellers asked urgently our customer service for help. The main reason was that the French CDiscount platform required them to fill in an EU authorized representative form. If the EU representative information form was not submitted to the seller’s backend before the deadline, the sellers’ product listing will be removed and cannot be promoted on the French e-commerce platform.
The EU authorized agent information requested by the CDiscount platform includes: company/legal person name, business address, contact number, product list, EU authorized representative name, address, signature, etc.
What is an EU authorized representative?
The new EU product safety regulations (known as the “EU Market Supervision Regulation 2019/1020”) will come into effect on July 16, 2021. This new regulation requires that products with the CE mark need to have a EU responsible person located in the EU as the point of contact for product compliance (that is, what we often call the “EU authorized representative”).
In other words, if the goods you sell carry the CE mark and are manufactured outside the EU, you need to affix the contact information of the EU responsible person on the product label. After July 16, 2021, it is an illegal act to sell CE-marked goods in the European Union in case the responsible person is not located in the European Union.
Check more about the cost and duties of EU representative service
What is the impact of not having an EU authorized representative?
As we all know, products that want to be imported to the EU market require CE certification, and it is illegal to import products without certification to the EU, and the seller’s products will be directly confiscated by the customs and face high fines. When the EU market supervision regulations are formally implemented, a CE certification without European representative is invalid thus likely to suffer the same consequences.
And this is only a punishment from the European Union. In order to monitor the safety of products and comply with relevant EU safety regulations, many e-commerce platforms in the European Union have removed and will also remove incompliant products and even close seller accounts in serious cases. Therefore, for cross-border sellers, it is extremely urgent to appoint your European representative and provide compliance information!
Of course, in addition to the active spot audits on the platform, many sellers have encountered complaints from competitors due to lack of information on EU representative, and failed to provide relevant information in time, resulting in products being removed from listing and losing market share.
Check more about Amazon compliance action to request DoC and EU representative
Which products need to have an EU authorized representative?
They are suitable for all kinds of products that require CE marking.
Check more about CE marking products compliance
What should I do if the product does not have CE certification?
CE certification is a European certification for product quality testing and compliance declaration. Products that have passed CE certification represent their quality recognized in Europe and can be circulated in Europe; and the EU authorized representative is the responsible person for the CE marked product compliance in the EU. In case of problems with the product in the EU, the EU authorized representative needs to assist in solving the issue.
Strictly speaking, a product without valid CE certification in the EU does not comply with the product safety law. It is illegal to enter the EU market. We will not act as an agent for products without verified CE certification.
Check our guidance on how sellers respond to the new EU market supervision regulations
Do you only provide European address?
Of course not, we are more than just providing addresses. Our clients know our difference. We spend time advising and guiding our customers in their product compliance journey with our expertise. Our responsibilities are as follows:
- A manufacturer outside the EU appoints an EU authorized representative established in the 30 member states of the EU EFTA to specifically represent the manufacturer outside the EU in dealing with the competent authorities and supervision agencies of 30 European countries.
- The name and address of the manufacturer’s EU authorized representative must be clearly printed on the packaging, label and instruction manual of the products affixed with the CE mark imported from outside the EU.
- “Technical files” must be stored in the EU authorized representative, and the EU authorized representative must save the latest Technical Files of all products affixed with the CE mark. According to EU law, the Technical Files can be provided to the CE supervisory authority in the EU for inspection at any time and in a timely manner. After the last batch of products is put on the market, the technical documents should be kept in the EU authorized representative for at least 5 years.
- Establish an “accident prevention and supervision system”. Manufacturers outside the EU must establish an effective “accident prevention and supervision system” within the EU, and provide assistance in accident reports, notifications, recalls, etc. of products through their EU authorized representatives.
In fact, before the implementation of the EU market supervision regulations, Amazon, eBay and AliExpress platforms have already issued compliance requirements and actively spot-checked users on their platforms regarding product compliance issues. Once spot-checked, they will be required to provide relevant compliance documents within the specified time. Therefore, the French CDiscount platform has made a new round of review requirements for product compliance issues, which also means that the EU has fully implemented market supervision regulations and gradually increased product compliance requirements.
Secondly, as we mentioned earlier, to conduct spot checks on the safety and compliance of electronic and electrical products, the Amazon platform has launched the UPSC plan, which is a project that specializes in managing upstream products. If the product is found to be under control in the list, it will be removed from the listing and required to provide relevant compliance certification documents in accordance with the specific regulations of the product (check this article for more information).
Of course, till now the audit practice applies to the single category of electrical and electronic products. But it is not ruled out that there will be a sampling plan for more categories in the future. We would like to remind all non-EU-based sellers who want to sell products to the EU market: Never neglect EU product compliance issues, and must do a strict supply chain control to have compliant testing for the CE-marked products. If you receive a compliance email from the e-commerce platform, you should contact our customer service in time to eliminate risks for your account and sales into the EU market.
Contact us for EU product compliance solutions.