INDUSTRY NEWS eu authorised representatives needed if you export to the european union


If you export to the European Union, you may be wondering what EU Authorised Representatives (ARs) are. Talk about ARs stems from the new European Union (EU) Regulation 2019/1020 on market surveillance and compliance of products. This came into force on 16 July 2021 with the aim of improving the ‘policing’ of markets in the EU to ensure products comply with applicable regulations and directives. Annex I of Regulation 2019/1020 lists approximately 70 product Directives that are affected by the new requirements. Examples from the industrial sector include: • 2006/42/EC Machinery Directive • 2014/30/EU Electromagnetic Compatibility (EMC) Directive


• 2014/35/EU Low Voltage Directive (LVD) • 2014/29/EU Simple Pressure Vessels Directive (SPVD)


• 2014/68/EU Pressure Equipment Directive (PED) • 2014/34/EU ATEX Equipment While Regulation 2019/1020 places obligations


on Member States and their market authorities, it also has important implications for manufacturers that export to the EU, including the UK. Specifically, Regulation 2019/1020 introduces new requirements relating to an ‘economic operator’. Without an economic operator established in the EU, you are prohibited from placing goods on the market. The economic operator is responsible for ensuring the conformity documentation is available, co-operating with market surveillance authorities and informing authorities if there are reasons to believe a product presents a risk. According to Regulation 2019/1020, an


economic operator can be any of the following: the manufacturer; the importer; an authorised representative; or a fulfilment service provider when none of the foregoing are established in the EU. Article 3 of the Regulation provides definitions for these four terms.


appoint an EU AR, Hold Tech Files is based in the Republic of Ireland and is therefore established in the EU as required by Regulation 2019/1020. The company offers a service whereby it acts as an AR for any of the Directives listed in Annex I. Although the Machinery Directive 2006/42/EC


If a manufacturer is based outside the EU, the


options for an economic operator are restricted to an importer, AR or fulfilment service provider. For industrial products or those where regulatory compliance is complex, it is unlikely that either the importer or fulfilment service provider will be competent or willing to take on the responsibilities of being the economic operator. Furthermore, if a manufacturer appoints an importer as the economic operator, this could entail sharing valuable intellectual property contained in technical files, which manufacturers will be reluctant to do. This leaves an AR as the only viable option. An AR is defined in Regulation 2019/1020 as any


natural or legal person established within the Union who has received a written mandate from a manufacturer to act on its behalf in relation to specified tasks with regard to the manufacturer’s obligations under the relevant Union harmonisation legislation or under the requirements of the Regulation. The AR needs to be competent to understand the conformity documentation and ensure it is suitable for purpose, and must be capable of responding to enquiries from market surveillance authorities. For manufacturers outside the EU needing to


predates Regulation 2019/1020, one of the Machinery Directive essential health and safety requirements (1.7.3) states that the machinery must be marked visibly, legibly and indelibly with the business name and full address of the manufacturer and, where applicable, his authorised representative. In effect, this means the AR’s details must be provided on the manufacturer’s plate on the machine. For machine builders, system integrators and


suppliers of safety components falling within the scope of the EU Machinery Directive, the new requirement in Regulation 2019/1020 for an economic operator is additional. Manufacturers outside the EU must still name a person established in the EU on the Declaration of Conformity (DoC) or Declaration of Incorporation (DoI) as being authorised to compile the technical file. For clarity, it would be advisable to name the person authorised to compile the technical file separately from the AR, even though it is simplest if both are, in fact, the same person. As well as being appointed as an AR, Hold Tech


Files can also be named on the DoC or DoI as the person authorised to compile the technical file. For this second service, Hold Tech Files has created a simple web-based portal where clients can sign a mandate, pay a fee and upload the relevant file to a secure server. The client is then entitled to name Hold Tech Files on the DoC or DoI for a period of up to ten years. This period can be extended, the files


modified or updated, and more products added. www.holdtechfiles.eu


design solutions mourns the passing of our dear colleague and great friend, paul munslow


It was with great sadness that the team at Design Solutions, and all the staff at Datateam Business Media, heard that our former colleague and great friend, Paul Munslow, had passed away suddenly at the end of November. Paul – or Munsie as he was affectionately known by so many – worked as the Northern Sales


Manager on Design Solutions (or OEM Design as it was called when he first started) from 1974 until his retirement in 2019, often joking that he was tempted into the job by the offer of a Ford Cortina. Very hard working, confident and with a great sense of humour, Paul loved his job, working tirelessly over the years in order to help Design Solutions to become a success. During his 45 year career on the magazine, Paul made many friends – both amongst his


colleagues in the company but also throughout industry, where he was well-know and very well-respected. In fact Paul particularly enjoyed meeting clients face-to-face, and was often seen at industry exhibitions and events where his incredible memory enabled him to remember faces, names, companies and even telephone numbers from across the years. Enjoying his job so much and the relationships he built with so many people over his time with


the company, Paul was very reluctant to retire. But in 2019, he eventually decided it was time to take things easy, and so retired in March of that year. Happily married with three daughters and 12 grandchildren, Paul loved spending his free time


with his family, tending his garden, and walking his West Highland Terrier. Meals out, weekends away and holidays were also a great source of pleasure to Paul. Paul will be greatly missed, with all those who had the pleasure to know him mourning his


passing, yet he will be remembered with incredible affection by all. Our thoughts are with his family at this very sad time.


DECEMBER/JANUARY 2022 DESIGN SOLUTIONS 7


Page 1  |  Page 2  |  Page 3  |  Page 4  |  Page 5  |  Page 6  |  Page 7  |  Page 8  |  Page 9  |  Page 10  |  Page 11  |  Page 12  |  Page 13  |  Page 14  |  Page 15  |  Page 16  |  Page 17  |  Page 18  |  Page 19  |  Page 20  |  Page 21  |  Page 22  |  Page 23  |  Page 24  |  Page 25  |  Page 26  |  Page 27  |  Page 28  |  Page 29  |  Page 30  |  Page 31  |  Page 32  |  Page 33  |  Page 34  |  Page 35  |  Page 36  |  Page 37  |  Page 38  |  Page 39  |  Page 40  |  Page 41  |  Page 42  |  Page 43  |  Page 44  |  Page 45  |  Page 46  |  Page 47  |  Page 48  |  Page 49  |  Page 50  |  Page 51  |  Page 52  |  Page 53  |  Page 54