Under CRA Art. 15, non-EU manufacturers who place products with digital
elements on the EU market must appoint an EU-based authorised representative.
Use this decision tree to determine whether this requirement applies to you.
Do you need an EU Authorised Representative?
Step 1 of 3
Is your organisation established in the EU or EEA?
If your company’s registered office, central administration, or principal
place of business is in an EU or EEA member state, you do not need an
authorised representative.
Step 2 of 3
Do you place products with digital elements on the EU market?
“Placing on the market” means making a product available for the first time
on the EU market. This includes selling, distributing, or making available
for download within the EU.
Step 3 of 3
Do you have an EU-based importer who handles market placement?
If you sell through an EU-based importer who takes on the CRA obligations
under Art. 18, they may fulfil some but not all of the functions of an
authorised representative. An authorised representative is still recommended
for direct regulatory contact.
What does an EU Authorised Representative do?
Regulatory contact point — Acts as the main contact for market surveillance authorities in the EU on behalf of the manufacturer.
Documentation access — Ensures the EU Declaration of Conformity and technical documentation are available to authorities on request (Art. 15(2)(a)).
Cooperation with authorities — Provides information and documentation to demonstrate product conformity. Cooperates on corrective actions (Art. 15(2)(b)).
Notification of risks — Informs the manufacturer immediately if there are reasons to believe a product presents a risk (Art. 15(2)(c)).
Mandate termination — If the manufacturer does not comply with CRA obligations, the representative must terminate the mandate and inform the relevant market surveillance authority (Art. 15(3)).
Mandate duration — The written mandate must cover the entire expected product lifetime or the support period, whichever is longer.
Track your CRA obligations
CRANIS2 manages all 35 CRA obligations across manufacturer, importer, and
distributor roles — including Art. 15 authorised representative requirements.