REG-REC-019 — EU Authorised Representative (CRA Art. 19)

This record has two parts. Part 1 is the applicability determination every manufacturer should file (so an auditor sees Art. 19 was considered, not missed). Part 2 is the written mandate example for the case where an Authorised Representative (AR) is required.

Part 1 — Applicability determination (example: EU-based KMU)

Determination, 2026-03-14: ACME Embedded GmbH is established in the European Union (Munich, Germany) and places all products with digital elements on the Union market under its own name. Art. 19 CRA (designation of an authorised representative) does not apply.

Watch item: Should ACME (a) begin selling products of the non-EU OEM "PacificSense Ltd." under the PacificSense brand, or (b) relocate its establishment outside the EU, this determination must be revisited. Note also the converse case: where ACME imports and rebrands non-EU products under its own name, ACME assumes manufacturer obligations itself — an AR does not substitute for that.

Approved: Managing Director (signed)

Part 2 — Written mandate (example for a non-EU manufacturer)

Scenario: ACME's non-EU sister company "ACME Embedded Asia Pte. Ltd." (Singapore) places the SensorNode S200-AP on the EU market and mandates an EU AR.

Mandate for an Authorised Representative pursuant to Art. 19 Regulation (EU) 2024/2847

Manufacturer: ACME Embedded Asia Pte. Ltd., 12 Science Park Drive, Singapore ("the Manufacturer")

Authorised Representative: EU-Compliance Partners GmbH, Musterstraße 8, 80331 Munich, Germany ("the Representative")

Products covered: SensorNode S200-AP (all hardware revisions), firmware series 3.x — as listed in Annex 1 to this mandate, updated by written notice.

1. Appointment. The Manufacturer appoints the Representative as its authorised representative in the Union for the products listed, for the purposes of Regulation (EU) 2024/2847 (Cyber Resilience Act). The appointment takes effect on 2026-09-01 for an initial term of 3 years, renewing annually unless terminated with 6 months' notice. Termination does not release the Representative from obligations concerning products placed on the market during the term.

2. Tasks of the Representative (minimum per Art. 19(3)). The Representative shall:
(a) keep the EU Declaration of Conformity and the technical documentation at the disposal of market surveillance authorities for at least 10 years after the relevant product is placed on the market;
(b) upon a reasoned request from a competent authority, provide that authority with all information and documentation necessary to demonstrate conformity of the product, in a language easily understood by that authority;
(c) cooperate with the competent authorities, at their request, on any action taken to eliminate the risks posed by the products covered by this mandate.

3. Obligations of the Manufacturer. The Manufacturer shall provide the Representative with the current DoC, technical documentation, SBOM references, and support-period statements no later than the date each product is placed on the market, and shall notify the Representative without undue delay of vulnerabilities, incidents, corrective actions, and recalls affecting covered products.

4. Limits. The obligations under Art. 13(1) (design, development and production in accordance with Annex I Part I) and the vulnerability-handling obligations under Annex I Part II remain with the Manufacturer and are not part of this mandate.

5. Identification. The Representative's name, registered trade name and postal address shall be indicated in the technical documentation and on the EU Declaration of Conformity for the covered products, and on the product or its accompanying documentation as required.

Signed for the Manufacturer: __________ (Managing Director, date)
Signed for the Representative: __________ (Managing Director, date)

Annex 1: Product list · Annex 2: Document hand-over log (DoC/tech-doc versions transmitted, dates)

Filing note

The signed mandate, Annex 1/2, and the current DoC copies are kept both by the Representative and in the Manufacturer's quality records. The technical documentation of each covered product references this mandate by ID (REG-REC-019).