EU & UK Economic Operator Support

An EU Authorized Representative is a legal entity established in the European Union who acts on behalf of a non-EU manufacturer to ensure compliance with EU regulations. The representative is responsible for maintaining technical documentation, cooperating with market surveillance authorities, and ensuring product compliance with EU requirements. Under the GPSR, having an EU Authorized Representative is mandatory for non-EU manufacturers selling products in the European market.

A UK Responsible Person (UKRP) is a legal entity established in the United Kingdom who acts on behalf of a non-UK manufacturer to ensure compliance with UK regulations. Following Brexit, the UK has established its own regulatory framework, and non-UK manufacturers are required to appoint a UKRP to place products on the UK market. The UKRP has similar responsibilities to an EU Authorized Representative, including maintaining technical documentation and cooperating with UK market surveillance authorities.

The General Product Safety Regulation (GPSR) introduces several significant changes compared to the previous General Product Safety Directive (GPSD):

• Enhanced traceability requirements throughout the supply chain
• Specific obligations for online marketplaces and e-commerce platforms
• Stricter product recall procedures and consumer notification requirements
• New requirements for digital products and connected devices
• Alignment with the EU Market Surveillance Regulation
• Mandatory requirements for economic operators based outside the EU
• Increased penalties for non-compliance

The General Product Safety Regulation (GPSR) entered into force in January 2024, with full compliance required by December 2024. This means that all economic operators, including manufacturers, importers, distributors, and online marketplaces, must ensure their products and processes comply with the GPSR requirements by this deadline. It's important to start the compliance process well in advance to ensure a smooth transition and continued market access.

The required documentation for EU and UK compliance typically includes:

• Technical documentation demonstrating product compliance
• EU Declaration of Conformity or UK Declaration of Conformity
• Risk assessment documentation
• Test reports and certificates
• User instructions and safety information
• Traceability documentation
• Post-market surveillance procedures
• Recall and corrective action procedures

The specific requirements may vary depending on the product category and applicable regulations. Our documentation review and preparation service ensures all necessary documentation is properly developed and maintained.

The GPSR introduces enhanced penalties for non-compliance, which can include:

• Substantial financial penalties (up to 4% of annual turnover in some cases)
• Product recalls and market withdrawals
• Temporary or permanent market bans
• Criminal proceedings in serious cases
• Reputational damage and loss of consumer trust

The specific penalties vary by member state, as each EU country implements its own enforcement measures. UK penalties are determined by UK authorities and may differ from EU penalties. Our compliance services help you avoid these penalties by ensuring full regulatory compliance.

Following Brexit, the UK has established its own regulatory framework, which has led to several differences from EU requirements:

• UKCA marking replacing CE marking for the UK market
• UK Responsible Person requirement instead of EU Authorized Representative
• UK-specific conformity assessment procedures
• Separate technical documentation requirements
• Different implementation timelines for new regulations
• UK-specific product databases and notification systems

While there are many similarities between EU and UK requirements, these differences require specific attention to ensure compliance in both markets. Our EU & UK Economic Operator Support service helps you navigate these differences efficiently.