How to Spot a Dodgy Authorised Representative
They all look legitimate until they're not.
Throw me a bone here Roger - What's an 'Authorised Representative' anyway? 🤷
If you're selling products in the EU as a non-EU business, you need someone physically established in the EU to act as your legal representative. They're the contact point for regulatory authorities, they hold your compliance documentation, and if something goes wrong, they're legally liable alongside you. It's required under what's know as GPSR (General Product Safety Regulation) and various product-specific regulations. Think of them as your official EU presence for compliance purposes.
The same concept applies in reverse—UK businesses selling in the EU need an EU Authorised Representative, and non-UK businesses selling in Great Britain need a UK Responsible Person. Same dog, different collar.
Now, here's the problem with choosing one:
Every AR website says the same thing:
"EU regulatory compliance" "Full GPSR support" "Experienced team"
You're selecting someone to hold legal liability for your products across 27 countries, and they all sound identical.
So you pick based on price. Or whoever responded fastest. Or whoever Dave mentioned in that Facebook group.
Six months later, you discover what you actually bought.
The compliance evaluation problem
A cheap accountant? You'll spot mistakes in weeks.
A bad 3PL? Customers complain immediately.
But an Authorised Representative? If they're filing paperwork incorrectly or missing regulatory updates, you won't know until enforcement lands.
By which point they've been enthusiastically signing off on your compliance whilst understanding approximately none of it.
What substandard ARs count on
Most sellers never get audited. Most products never trigger enforcement.
So they can operate for years without consequences, because the probability of any individual client getting caught is genuinely low.
Until you get big enough to bother someone with a legal department.
Big Pharma doesn't appreciate supplement brands nibbling at their market share. Beauty conglomerates notice when indie brands trend. Aggregators actively hunt for documentation gaps in competitor listings.
They don't report you to regulators. They sue you directly.
Regulatory enforcement is random and rare.
Competitor legal action is targeted and increasing.
Market surveillance authorities use these checks to identify problematic ARs. Make sure yours passes.
The obvious red flags
Virtual office addresses - If you can't visit them, regulatory authorities can't either.
"We cover all product categories" - Claiming expertise across everything means shallow expertise across everything.
The agency bundle - If they also offer PPC, listing optimisation, and fulfilment, compliance is the upsell.
The less obvious ones
The €500/year mystery
An AR charging €500 annually needs 100+ clients to pay one compliance professional.
That's roughly 20 hours per year, per client, for all monitoring, documentation, and enforcement response.
Either they've cracked some efficiency code nobody else has found, or they're relying on some AI program that would be utterly flawed, or they're providing 20 hours of work and hoping you don't notice.
The November 2025 reality check
In November 2025, the EU published detailed GPSR implementation guidelines that changed the compliance baseline.
Pages 36-38 spell out what Responsible Persons must actually do:
"Regularly check" that products comply with technical documentation
Provide "documented evidence of the checks performed" to authorities on request
Verify that identified risks are actually being mitigated as described in documentation
This isn't a one-time review at onboarding. It's ongoing.
The question for budget AR services:
If you're paying €500/year and they have 100+ clients, when are they performing these regular checks? Where are the documented records?
Most budget services were designed for the old interpretation where having an EU address was enough.
The November guidelines make clear that's not sufficient anymore.
The cheapest AR option often becomes the most expensive mistake
The vague expertise test
Ask: "What testing standards apply to liquid products under CLP?"
If they pause to Google it, they're winging it.
Real compliance professionals answer in regulation numbers and explain why requirements exist.
The geography trap
If you're selling in both UK and EU markets, ask: "Can you represent products in both territories?"
A Berlin-based AR can handle EU. Cannot touch UK.
A Manchester-based RP can handle UK. Cannot touch EU.
Your representative must be "established in" the territory. It's a legal requirement.
Most sellers hire two providers because they don't realise geography creates this limitation.
Now you're managing two compliance relationships, two sets of documentation, two addresses on packaging.
Unless you're talking to someone in Northern Ireland.
The Windsor Framework quirk
We all know Brexit has stunk the place out. However it does have one juicy perk. Northern Ireland operates under dual regulatory status:
Subject to UK law → can be UK Responsible Person
Aligned with EU rules → can be EU Authorised Representative
One provider. Both markets.
This isn't a loophole—it's how the protocol works.
Most sellers don't know it exists because Northern Ireland is small and easy to overlook, and most compliance providers are based where this doesn't apply to them.
The EU published detailed GPSR implementation guidelines in November 2025. These guidelines make explicit what "proper" AR service actually requires - including regular compliance checks with documented evidence. This raises the bar significantly from what budget services were designed to provide. See pages 36-38 of the guidelines for details.
Questions that separate real from pretend
"Can you show me evidence of the regular compliance checks you perform?"
"How do you document your review process for authorities?"
"Can I see your office on Google Street View?"
"Which specific product categories do you specialise in?"
"Who handles regulatory monitoring for my account?"
"What happens if I receive an enforcement notice?"
"Can you represent in both UK and EU markets? If so, do I need to add both addresses on my packaging?"
"What regulatory changes affected my category in the past 6 months?"
Vague responses = selling reassurance
Specific answers = actual expertise
What you're actually buying
An AR accepts legal liability for your products.
Good ones price for that risk. Bad ones assume probability stays in their favour.
You don't need your AR 99% of the time.
You need them for the 1% when everything's on fire 🔥.
Choose accordingly.
Not sure if your current AR setup is actually protecting you? Get in touch to discuss. No obligation, just clarity.
