EU Authorised Representative

For product conformity and the EU DPP Registry — not extended producer responsibility.
Union law requires that someone established in the Union answer for your products to market surveillance authorities. Article 4 of Regulation (EU) 2019/1020, extended to batteries by the Battery Regulation, allows that to be an EU importer or an authorised representative appointed under a written mandate. A manufacturer established outside the Union is not on that list. This page is about what that role actually is.

Why someone in the Union must carry it

Not a platform limitation — a legal one. Article 4(1) of Regulation (EU) 2019/1020 allows a battery to be placed on the Union market only if an economic operator established in the Union answers for it. Article 4(2) sets out who that may be: an EU manufacturer, an importer, an authorised representative under written mandate, or a fulfilment service provider.

What an authorised representative does

Acts for you on the EU market under a written mandate: holds the verified identity in the Registry, carries the obligations that attach to the responsible operator, and is the address authorities turn to.

What you still own

The product data. Materials, carbon footprint, recycled content, substances, documents — that is your technical documentation, and nobody else can author it. You bring it in whatever shape you have it.

Already have an EU importer?

Your importer can hold the verified status and authorise us purely as the DPP service provider.

What we are, and what we are not

The roles around a passport are confused with one another constantly.

We are not a producer responsibility organisation

A PRO collects contributions from producers and organises the collection, treatment and recycling of waste. We do none of that. The EPR authorised representative under Article 56(3), registration in national producer registers and recycling contributions are a different role under different rules, and we do not take it.

And we are not your importer

We are not importer of record, we do not clear customs, and we do not assess, test or certify your products. Drawing up your technical documentation stays with you — Article 40(2) does not allow it to be delegated to a representative at all.

If you need a producer responsibility organisation as well, we will introduce you to one in each Member State concerned. That is a separate contract between you and them.