UK has become a third country, in EU parlance. Manufacturers in third countries have always been permitted to place recreational craft products on the European (Economic Area) market without a local representative. A manufacturer may, however, choose to have a formal Manufacturer’s Authorised Representative in EEA.

If a manufacturer chooses to have an Authorised Rep, they must:

  1. be located within EEA (so UK companies that were previousl reps for CE marked products cannot do play this role any longer)
  2. sign the formal Declaration of Conformity – not the manufacturer, though both should be identified
  3. make the formal technical documentation available to European authorities, should they ask for it

An authorised rep is responsible for making documentation available but it not actually liable for the product itself. This always remains with the manufacturer. (Though wilful or gross negligence on behalf of the rep would attract liabilty).

Everything said above works the other way around. So a European based representative cannot play the same role for a product being sold into UK.

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