Uk Authorized Representative Service

Scope and evidence must be confirmed before any paid tests or filings.

A UK authorised representative (UK AR) is a person or business established in the UK and appointed in writing by a manufacturer for defined product-regulatory tasks. It is not an automatic licence to sell in Britain, a substitute for the importer, or a universal requirement for every overseas manufacturer. First identify the product rules and destination; then decide whether to appoint and exactly what to delegate.

Is a UK authorised representative required for your GB product?

Apply this triage by product family and market. “Usually optional” means a written mandate is permitted, not that the product itself is exempt from compliance. The applicable instrument always controls.

Product / market	Representation decision	Safe next step
GB electrical equipment, EMC apparatus or RoHS electrical/electronic goods	An AR may be appointed under the relevant GB legislation; appointment is not inherently compulsory solely because the manufacturer is overseas.	Verify every applicable regime, identify the GB importer and define any administrative mandate.
GB radio equipment	GB regulation 19 permits a UK-established representative by written mandate; core design and conformity-assessment duties cannot be delegated.	Check radio, EMC, safety and other applicable requirements before allocating tasks.
GB medical devices from a manufacturer outside the UK	Different statutory role: a UK Responsible Person is required for GB access under MHRA rules.	Use the medical-device-specific appointment and registration route, not an ordinary UK AR contract.
GB cosmetics	Different statutory role: a UK-established Responsible Person is required. For ordinary GB imports the UK importer is the Responsible Person by default, unless an eligible UK-established third party accepts a written mandate; qualifying NI goods have special rules.	Identify the Responsible Person, product information file and notification obligations.
GB chemicals / UK REACH substances	Different role: an eligible overseas business may appoint a GB-established Only Representative; this is not the ordinary product AR role.	Assess substance, importer and registration duties separately.
Northern Ireland or EU as destination	A GB-only AR cannot be assumed to cover NI/EU. Rules for NI and the EU differ from GB.	Map the exact sales territory and arrange suitable representation only where required.

UK AR mandate: duties that may and may not be delegated

A written mandate is a controlled delegation, not a transfer of the manufacturer’s compliance responsibility. Authorities and sectors can impose different minimum tasks. For example GB EMC and RoHS guidance restricts what may be delegated; the government’s general guide lists other tasks that may be possible when sector legislation allows them.

Activity	Manufacturer / importer	Possible AR assignment
Design, manufacture, risk assessment, conformity route	Manufacturer retains substantive responsibility.	Do not promise to take over essential design or statutory assessment duties.
Technical file and declarations	Manufacturer creates/ensures correct evidence; importer has its own checking and retention duties.	Keep or make documents available and transmit them to regulators within the actual mandate.
Authority enquiries, suspected hazards, corrective action	Manufacturer and importer retain applicable legal duties.	Receive, escalate, cooperate and track responses; the manufacturer, importer and representative must each discharge their own applicable duties, including corrective action where required.
Declaration signing or marking	Only if the product rules permit delegation and the evidence supports it.	Explicitly specify authority; no blanket promise to issue a UKCA certificate.
Importer name, traceability and supply chain	Importer retains importer obligations even if also appointed AR.	Never replace required importer identification merely by printing the AR address.

Regime-specific mandate test: Under the GB Radio Equipment Regulations 2017, regulation 19, the mandate must cover retention of technical documentation/declaration and provision of information and cooperation with authorities; design, conformity assessment, and the duties concerning the UK declaration and UK marking under regulation 10 cannot be delegated. GB EMC mandates also have compulsory record-access tasks. GB RoHS representation is strictly administrative: it must not be sold as authority to create the technical file or verify production controls. For GB EMC, radio and RoHS, a representative may be established in Great Britain or Northern Ireland, but not solely outside the UK. Check the specific legislation before signing.

Private-label trigger: A UK importer or distributor that markets a product under its own name or trademark, or changes it in a way that affects compliance, can acquire the legal obligations of a manufacturer. An AR appointment cannot neutralise that change of role.

UK AR appointment: product and importer evidence checklist

Before quoting or accepting the engagement, obtain enough information to identify the correct legal role and product scope:

Legal manufacturer identity, brand owner, registered location and the proposed UK representative’s establishment details.
SKU/model list, function, intended users, variants, risk characteristics and product photographs.
Exact destinations: England/Scotland/Wales, Northern Ireland and/or EU; first supply date and distribution chain.
Names of GB importers, distributors and any private-label operator; current label/address artwork.
Regulation-by-regulation applicability map, available UK/EU declarations, certificates, test evidence and technical files.
Contact person, document access method, language, known incidents, outstanding regulator requests and planned changes.

UK AR service deliverables: mandate, records and regulator response

A meaningful service engagement should produce these operational outputs:

Role determination: written note stating whether an AR is permitted, needed or inappropriate for each product/market; unresolved assumptions are flagged.
Mandate: signed manufacturer–representative agreement listing products, covered regulations, delegated tasks, exclusions, authority and effective date.
Document register: controlled index of declarations, technical files, versions, owner, access permissions and regime-specific retention periods.
Regulator-response protocol: contact route, evidence retrieval, escalation owner and handling of safety concerns or recall requests.
Handover and exit: process for new models, updated labels, replacement representative and continuing statutory record access.

Changing or ending a UK AR mandate: why an address is not enough

Require documented notification of product redesign, firmware or radio changes, new standards, new importer, country expansion, incident or regulator letter. Reassess the mandate and conformity evidence before assuming the existing coverage still works. There is no universal AR subscription duration, statutory service fee or automatic UKCA approval: contract price and scope are commercial, while record-retention periods come from the applicable regulation (often, but not always, ten years).

A UK address alone proves neither conformity nor an AR appointment. Do not advertise “mandatory UK AR for all CE goods”, presume that EU Regulation 2019/1020 governs GB, or assume that a CE/UKCA mark identifies who must act as importer or representative. In many sectors GB continues to recognise CE marking, but scope and conditions must be checked by product.

When a different UK regulatory role is required

Use the following neighbouring pages only for their separate delivery tasks:

For medical devices and other specifically defined local-responsibility roles, examine UK Responsible Person service.
For the EU/EEA appointment rather than a GB mandate, see EU authorised representative service.
For the full GB market-entry and operator map, see UK market-access overview.
For chemical Only Representative versus registration execution, see UK REACH registration service.
For conformity assessment, marking and evidence development, see UKCA marking service.
For medical-device-specific representation, use UK medical-device responsible person service.

Next safe action: send the product list, intended territory, manufacturer/importer map, existing declarations and technical evidence. Ask for a written role determination and a draft, product-limited mandate before paying for representation or changing packaging.

UK AR FAQs: radio equipment, importers and markets

We are an EU manufacturer selling CE-marked consumer electronics into GB: is a UK AR always obligatory?

No general rule makes it obligatory merely because the manufacturer is in the EU or the device bears CE. Check the specific GB electrical, EMC, radio and RoHS rules, together with GB importer obligations; an AR may be voluntary.

Can our British importer also be our authorised representative?

Potentially, if established in the UK, properly mandated and permitted by the product regulations. That does not extinguish its importer obligations; document both roles separately.

Can the UK representative sign our Declaration of Conformity or apply UKCA marking?

Only where the applicable product rules allow the particular task and the written mandate grants it. The representative cannot replace mandatory testing, necessary technical evidence or manufacturer accountability.

Will one GB appointment cover Belfast, Dublin and Paris?

Do not assume so. Northern Ireland and EU rules differ; a representative established only in GB does not automatically qualify for their regimes. Assess NI and EEA coverage separately.

What happens if we change representative or add a new product model?

Check whether the mandate covers that model, transfer or preserve regulator access to required records, update agreed contact/label information where legally necessary, and keep a traceable appointment history.

For GB radio equipment, can the representative prepare and sign the UK declaration or take over conformity assessment?

No. For the GB Radio Equipment Regulations 2017, regulation 19 excludes the design, technical-documentation/conformity-assessment and regulation 10 declaration/UK-marking obligations from the mandate. The mandate must instead include record retention and cooperation/information duties. Check any other applicable product laws separately.

Official GB legislation and guidance

Check the actual product legislation alongside this official guidance; the headings below identify the authority, not a guaranteed outcome.