Certification or Declaration Under TR CU 018
Three conformity assessment forms, two of which apply to parts. Where responsibility sits in each, and what decides which one your product takes.
Local presence
Authorised representative
For representation, the first reply says which markets on your list require a local operator and what that operator is liable for.
How it works
Five steps from an inquiry to a registered certificate
You send the request
Product name, HS code and technical data, enough for us to scope the route.
Your part
We confirm the route
A specialist confirms the regulations that apply and the document type your product needs.
Our part
Documents and contract
You send the supporting documents; we sign a contract with fixed scope and timeline.
Both sides
Testing and inspection
Laboratory testing, factory inspection and customs clearance, coordinated by us.
Our partYou receive the certificate
Issued, registered, and delivered. We close the project.
Your part
- One named specialist One person owns your file from the first email to the registered certificate.
- Route fixed before testing Scheme, standard and laboratory are settled before a sample is tested, which is where most re-testing starts.
- Registered documents Certificates and declarations issued by accredited bodies and entered in the official register, where customs can look them up.
- Measured by the document The engagement ends when the certificate is issued and registered, whatever the hours took.
The short answer
Where a foreign manufacturer cannot apply alone
Several major schemes cannot issue a certificate to a foreign manufacturer at all. The Eurasian Economic Union requires an applicant registered in a member state; Brazil requires a company holding a CNPJ; the European Union and the United Kingdom each require an economic operator established locally, named in the documentation and reachable by the market surveillance authorities. These are legal appointments carrying real obligations, not mailboxes. Where a client has no local entity we act as that representative, which also means the certificate does not have to be reissued when a distributor changes.
- EAEU and Brazil The Eurasian Economic Union requires an applicant registered in a member state. Brazil requires a company holding a CNPJ.
- EU and UK Each requires an economic operator established locally, named in the documentation and reachable by the market surveillance authorities.
- Appointments, not mailboxes These are legal appointments that carry real obligations.
- We act as your representative Where you have no local entity, we act as that representative, and the certificate does not have to be reissued when a distributor changes.
Who must be local
The EAEU needs an applicant registered in a member state, and Brazil a company holding a CNPJ. The EU and the UK each need an economic operator established locally and named in the documentation.
Arrange it at the route assessment, in parallel with testing and the file.
What the role obliges
Regulation (EU) 2019/1020 requires a responsible economic operator in the Union for a range of products. That operator keeps the declaration and technical documentation available and cooperates with the authorities.
The technical file, risk assessment and evidence stay the manufacturer's responsibility.
Who holds the document
In the EAEU the applicant is the holder, and the certificate or declaration is issued in its name. A distributor named as applicant can amend it and keeps it when the contract ends.
A new distributor then means a new application and a gap in shipments.
Already started elsewhere
Replacing the representative or distributor named on your certificate?
This route stops in two places. The first is the last step of a finished project: the file is complete, testing is done, and no established party exists to name as applicant, so the schedule waits for a company formation or a representation agreement. The second comes later, when the distributor named as applicant is the party you are leaving, and it holds the document, the right to amend it and your technical evidence.
It turns on what the local party holds. An EU authorised representative keeps the declaration and technical documentation available to the authorities, so a change of representative is a matter of paperwork. An EAEU applicant holds the certificate or declaration itself, in its own name. Changing that party means a new application, frequently new testing where the reports were commissioned in the previous holder's name, and a period when the product cannot ship.
What we handle
- The appointment itself
- Document custody
- Correspondence with authorities
- Continuity across distributor changes
What to send us
Everything here is something to find before the project starts. The first reply says which of it can go into the file as it is.
- The certificate or declaration of conformity, showing the applicant or holder named on it
- The technical documentation
- Product and contact details
- A mandate, and your current agreement with any representative or distributor
- Every market you sell in, with the UK listed separately from the EU
- Who commissioned the test reports, and in whose name they were issued
- 2010 Year of foundation
- 1300+ Certification projects
- 40+ Countries served
- 15+ Types of certificates
The people on your file
Meet the teamYou will know the person who handles your certificate.
One specialist owns your file from the first email to the registered certificate. Every one of them has recorded a briefing on their field.
Services
What we do on this route
Each stage is a service of its own, with a page that says what it produces and what it needs from you.
Route assessment
The cheapest stage decides the cost of every stage after it. What a route assessment names, and the four decisions it locks down.
Read the pageProduct testing
Accreditation is per standard and per laboratory, never general. How to choose one the destination accepts, and test once for several markets.
Read the pageTechnical documentation
The file is the certificate’s foundation and it is the manufacturer’s to produce. What it has to contain, and what cannot be written retrospectively.
Read the pageAudit & training
Audits turn a schedule from weeks into months and cannot be compressed. What auditors check, and how to be ready for the first visit.
Read the pageMarking & labelling
A correct certificate and a wrong label still stops at the border. What each market demands on the artwork, and when to check it.
Read the page
What the appointment actually obliges
In the European Union the obligations of an authorised representative are set out in the legislation and in Regulation (EU) 2019/1020, which requires that for a range of products no product may be placed on the market unless there is an economic operator established in the Union responsible for it. That operator keeps the declaration of conformity and the technical documentation available for the authorities, cooperates with them, and takes action where a product presents a risk. The United Kingdom mirrors the shape through its own responsible person for the UKCA regime.
The Eurasian Economic Union goes further in one respect: the applicant is not merely reachable, the applicant is the holder. The certificate or declaration is issued in the name of a legal entity or individual entrepreneur registered in a member state, and that party carries the obligations of the person who placed the product on the market.
Brazil sits in the same family. Certification runs through a company with a CNPJ, and for the health-regulated categories a locally registered holder is a condition of the registration rather than a convenience.
None of this makes the representative liable for the design. The technical file, the risk assessment and the evidence remain the manufacturer’s, and the representative’s duties run to holding, producing, cooperating and acting. What it does mean is that the appointment is a contract with defined obligations on both sides, and one that a signature block on an invoice does not create.
Why the distributor is usually the wrong holder
Naming the importer as the applicant is the cheapest arrangement on day one and it is what most first projects do. The cost arrives later, and it is structural rather than financial: the certificate is tied to a commercial relationship. The holder is the party the authority deals with, the party that can amend the document, and the party that has to consent to anything being done with it.
When that relationship ends, the certificate does not travel. A new distributor means a new application, frequently new testing where the reports were commissioned in the previous holder’s name, and a gap during which the product cannot be shipped. Manufacturers discover this at the worst possible time, which is when they are already changing distributor because something has gone wrong.
The second cost is negotiating position. A distributor who holds the market access document holds the market. Renewal conversations with a distributor who knows that are different conversations, and the manufacturer has no alternative that does not involve re-certifying from the start.
The third is confidentiality. The technical evidence — the bill of materials, the schematics, the test reports — sits with the holder, and in this arrangement the holder is a company that may also represent a competitor.
What it costs, and where it belongs in a budget
Representation is a recurring annual cost rather than a one-off, and it is the item most often missing from a first estimate. Over three years the combined cost of representation and certificate renewal often exceeds the initial project cost, which is not an argument against it — it is an argument for it appearing in the model at the point the market is chosen rather than at the point the certificate is nearly ready.
It is also the item that most often stops a project at the last step. A file complete, testing done, application ready, and no established entity to name as the applicant — at which point the schedule waits for a company formation or a representation agreement that could have been arranged in parallel from week one.
Who has to be established locally, and as what
| Market | Required party | Holds | Nature of the cost |
|---|---|---|---|
| European Union | Authorised representative or responsible economic operator | Declaration of conformity and technical documentation, available to authorities | Annual, ongoing |
| United Kingdom | Responsible person established in the UK | Declaration and documentation for UKCA | Annual, ongoing |
| Eurasian Economic Union | Applicant registered in a member state | The certificate or declaration itself, in its own name | Annual, plus reissue on change |
| Brazil | Company holding a CNPJ | The certification, and the registration where applicable | Annual, ongoing |
| Saudi Arabia | Importer with a Saudi commercial registration | The SABER account and the certificates raised under it | Per product and per shipment |
| United Arab Emirates | Local importer or representative | The registration under the scheme | Annual, ongoing |
The column that matters commercially is the third one. Wherever the local party holds the document rather than merely holding a copy of it, changing that party means re-certifying rather than re-papering.
Frequently asked questions
Is an authorised representative the same as an importer?
No, and the distinction is the point. An importer is whoever brings the goods in and has its own obligations. An authorised representative is appointed by the manufacturer under a written mandate to perform specified tasks — holding the declaration and the technical documentation, cooperating with the authorities, acting where a product presents a risk. One party can be both, which is exactly the arrangement that causes trouble when the commercial relationship ends.
Can our distributor be the applicant?
In most schemes yes, and it is the cheapest option on day one. What it buys later is a certificate tied to that relationship: the distributor can amend it, has to consent to its use, holds your technical evidence, and takes it with them when the contract ends. Where more than one distributor is planned, or where the relationship might change, an independent holder costs less over three years than one re-certification.
Does using you as representative make you liable for our product?
The duties of a representative run to holding the documentation, producing it for the authorities, cooperating with them and acting where a product presents a risk. The design, the technical file, the risk assessment and the evidence behind them remain the manufacturer’s, and the mandate says so. What the appointment does is give the market a party it can reach — which is what the legislation is asking for.
We already have an EU subsidiary. Do we need anything?
Probably not for the European Union, provided the subsidiary is genuinely established there and is named in the documentation. Check the United Kingdom separately: since UKCA it is its own regime with its own responsible person, and an EU entity does not satisfy it. That split catches manufacturers who set up their European arrangement before it existed.
When should this be arranged?
At the route assessment, in parallel with everything else. It is the item that most often stops a finished project at the last step — file complete, testing done, and no established party to name as applicant. Arranging representation takes days; forming a company does not, and neither does re-running an application under a different name.
Keep reading
On representation, importers and holding a certificate
Certifying Water Heaters, Lighting and Appliances
Which household products declare, which certify, and why an exemption letter is worth having at customs.
TR CU 020: Electromagnetic Compatibility Explained
What falls inside the EMC regulation, which products certify and which declare, the three certification schemes, and the two exclusions worth knowing.
Sources
- Regulation (EU) 2019/1020 on market surveillance and compliance of products — EUR-Lex
- Placing manufactured goods on the market in Great Britain — GOV.UK
- Department for Technical Regulation and Accreditation — Eurasian Economic Commission
Tell us what you are exporting
Send the product name, HS code and technical data. You get back the applicable route, the document list and a timeline, before any commitment.