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CE marking – Responsible Agents


I’ve had some creators reach out to me and ask about Responsible Agents in relation to CE marking, specifically paid Responsible Agents. As such I’ve tried to look into the subject and form some conclusions that might be helpful.

Traceability

Firstly, to explain why you would need a Responsible Agent. CE marking, and the general regulations for selling in the EU anyway, require that you have a business address of a business in the EU on your box. Technically it requires that you have it on every single element of whatever’s in your box also, but that is left up to the individual producer to achieve as far as is practical. It also requires that you have the address of the ‘manufacturer’, slightly confusingly that’s whoever orders it to be manufactured, rather than the factory that physically makes it. If one address can do both of those things, then that’s great.

But what happens if your address as the ‘manufacturer’ is outside the EU? Not a problem, you simply put your address and the address of the importer who is shipping your goods into the EU. The logic behind the legislation is pretty clear, if something goes wrong, they want someone with a vested interest in the project to be traceable and answerable, and it’s a lot easier for the EU to make a business in the EU answer to their regulations than one outside of it. If an importer is shipping pallet loads of your product in the EU to the point where they are paying thousands in duty, either for themselves before selling your product on or on your behalf before shipping out to backers, clearly they have a real contracted relationship with you that the EU can then use if something goes wrong to make someone answer for the problem. The EU is fine with that importer’s address being on a stick on label, so if you’re outside the EU and shipp