5. Obligations of authorised representatives
Manufacturers are able to appoint authorised representatives to perform certain tasks on their behalf.
Mandated authorised representatives for the GB market can be based in GB or NI but cannot be based outside the UK. A manufacturer can only mandate an authorised representative established in the UK, under the 2017 Regulations as they apply in GB.
No GB-based authorised representatives are recognised under EU law. This means GB-based authorised representatives cannot carry out tasks on the manufacturer’s behalf for products being placed on the NI and EEA markets. Therefore, a GB manufacturer selling products to the EEA or into NI, who wishes to appoint an authorised representative to carry out tasks for them in respect of those products, must appoint an authorised representative established in NI or the EEA.
An authorised representative must comply with all the duties imposed on the manufacturer under the 2017 Regulations that they are appointed by the manufacturer to perform. The manufacturer remains responsible for the proper performance of any obligations the authorised representative performs on their behalf.
Any references in the 2017 Regulations to the manufacturer are to be taken to include a reference to the authorised representative including in relation to penalties for failure to comply with those duties.
6. Obligations of importers
An importer is a person or business based in the UK who places products on the GB market from a country outside the UK. This means that a UK business which acted as a ‘distributor’ before 1 January 2021 is now legally an ‘importer’ if they place products from an EEA country or Switzerland on the GB market and therefore must comply with the importer duties under GB legislation.
This includes products that are supplied to NI businesses from the EEA and then placed on the GB market. In this instance the NI business will take on importer obligations for EEA-supplied goods that are placed on the GB market (see also section 10 on Qualifying NI Goods).
Importers have additional legal obligations which go beyond those of distributors, such as checking that manufacturers have carried out the required conformity assessment procedures and including their (the importer’s) name, registered trade name or mark and a postal address on the equipment.
Importers need to ensure that their address appears on the product or in accompanying documentation. Where it is not possible to indicate the information on a component, the importer can set out their details on the packaging or in accompanying documentation. To assist with the transition, the UK is applying a transitional period ending on 31 December 2027 to allow UK businesses who import from EEA states (and from 1 January 2021 become importers into the GB market) to provide their details on the accompanying documentation as an alternative to placing them on the product itself. This applies to goods that are not qualifying NI goods. For further detail on qualifying NI goods, please see section 10 on Qualifying NI Goods.
The obligations of importers include:
1) Before placing a product on the market or putting it into service, an importer must ensure that: - a) the relevant conformity assessment has been carried out by the manufacturer. This means that the product must comply with the requirements in Schedule 1.
- b) the manufacturer has drawn up the technical documentation. - c) the product has the relevant conformity assessment marking affixed and is accompanied by the required documents.
- d) the manufacturer has complied with the labelling requirements imposed on the manufacturer.
2) When the importer has reason to believe that a product to which the Regulations apply is not in conformity with the essential requirements, the importer must not place the product on the GB market.
3) The importer must ensure that when placing products on the GB market, that they are accompanied by instructions which are in English.
4) The importer must provide their name, registered trade name or registered trademark and a postal address at which they can be contacted on the product. Where the product is a component and it is not possible to indicate this information on the component itself, the information may be provided in a document accompanying the component or on the component’s packaging. Where the importer has imported the product from an EEA state or Switzerland and places it on the GB market before 31 December 2027, the information may be provided in an accompanying document.
66 | ISSUE 115 | MAR 2026 | THE REPORT
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