EU Authorized Representative Service

for non-EU manufacturers

The new Market Surveillance Regulation 2019/1020 came into effect in the EU on July 16, 2021. It stipulates, among other things, that products may only be marketed in the EU if there is an economic operator established in the EU who is able to present any and all information and documents pertaining to compliance with the relevant provisions to the authorities upon request. This is precisely the service that we at Tradavo Compliance provide for your company, i.e., we provide the address of our company registered in Germany, and we act as point of contact for authorities within the EU.

Details of the procedure

1.

We check your product portfolio for compliance with the provisions applicable in the EU

2.

If necessary, we help you to eliminate any deficiencies identified in regard to such compliance

3.

You get the address of our German company, which you can then affix to your products / packaging

4.

The importation into the EU can now be effected by way of indirect customs representation

What is important when importing into the EU?

Your products are imported from third countries by way of the so-called indirect customs representation. This method of importation has various advantages both for you as the seller and for us as your EU authorized representative. Probably the most important advantage for you: You are and remain the owner of the goods to be imported at all times! The title to the goods is not transferred to us, even temporarily, for the purpose of customs clearance at any time during the import process. Furthermore, your company name is the only name indicated on the corresponding import documents, e.g., the bill of lading, giving you full control over the import at all times, while any and all issues regarding taxes and customs duties are provided for and legally incontestable.

As mentioned above, we are not directly involved in the import process as such, which is why we have taken a strong and reliable partner for this purpose: UNICON Logistics

If you import your products with the help of our long-term partner UNICON Logistics, you can be sure that your goods are in good hands, and that the import process is executed quickly, properly, and incontestably. Do you want to know more about indirect customs representation or importation in general? Just contact one of the staff of UNICON Logistics listed below and give them our regards. They are looking forward to hearing from you.

Malte Friedrichsen

Julian Römer

+49 421 59688 665
j.roemer@unicon-ecommerce.de

Catrin Fock

+49 421 59688 658
c.fock@unicon-ecommerce.de

What kind of fee can I expect to be charged?

Product portfolio compliance check

Price per product
from 100 €* plus VAT (if applicable)
  •  

*The final fee depends on the complexity of the respective product and the number of products (volume discount).

Authorization

Annual fee for the use of our business address
from 500 €** per year plus VAT (if applicable)
  • German business address
  • Unlimited import volume
  • Title to the goods remains with the seller
  • Assumption of communications with authorities
  • Contractually secured under German law

**The final annual fee depends on the risk assessment, the number of products and the annual import volume.

Elimination of deficiencies

Price per product (laboratory fees not included)
from 150 €*** plus VAT (if applicable)
  • Review of instructions and artwork

***The final fee depends on the complexity of the respective product, the scope of the deficiencies that need to be addressed, and the number of products (volume discount).

Frequently asked questions of our clients

1. What is an EU Authorized Representative and why do I need one?

An EU Authorized Representative is your official point of contact for regulatory authorities within the EU. If your company is based outside the EU and you want to sell physical products on the EU market, you'll likely need an EU-based economic operator who can provide authorities - upon request - with the documentation and information needed to demonstrate product compliance.

2. Who is Tradavo's EU Authorized Representative service a good fit for?

Our service is built for companies headquartered outside the EU that want to sell or import products into the EU under their own brand and need both an EU address and a reliable point of contact for authorities to make that happen.

3. How quickly can we get the EU Authorized Representative service up and running?

It depends on how fast you can get us the necessary documents and how complex your products are. In our initial consultation, we'll walk through your timeline together and give you a realistic picture of when we can kick things off.

4. Can I use the service for multiple products or an entire portfolio?

Absolutely, that's exactly what the service is built for. We'll review your portfolio in a structured way, and if you have a larger number of products, volume discounts are often available depending on scope and complexity.

5. How does pricing work if I have multiple products?

The Authorized Representative service starts at 500€ per year. Having more products doesn't automatically mean higher costs. If your products are straightforward from a compliance standpoint, you'll often stay right at that 500€ mark. Put simply, the annual fee is largely driven by the risk profile of your products. We'll take a close look at your portfolio and put together a fair quote.

6. Does Tradavo act as the importer or handle customs clearance?

No. Those aren't roles we take on. As your EU Authorized Representative, we don't act as the importer of record or manage customs ourselves. You'll typically handle your imports through a logistics partner (such as UNICON Logistics) using indirect customs representation, which keeps you in full control and ensures you remain the owner of your goods throughout the process. You'll also need your own EORI number for this, which you can register for free, for example, through German Customs.

7. What's the benefit of indirect customs representation for me?

The biggest one: you stay the owner of your goods at all times. Your company also remains the named party on all import documents (like the Bill of Lading), so you keep full visibility and control over the process and everything stays clean from a tax and customs standpoint.

8. Are there products you won't provide EU Authorized Representation for?

Yes. We don't provide EU Authorized Representation for product categories including food, animal feed, cosmetics, and medical devices. This isn't just an internal policy, it's a legal matter. For some categories, appointing an EU Authorized Representative under Market Surveillance Regulation (EU) 2019/1020 is not permitted, as they fall under their own specialized regulatory frameworks with different requirements and responsible parties.

9. Does the authorization apply only in Germany or in every EU country?

If you use our business address, we will act as your authorized representative for your products within the entire European Union, and represent you in the case of inquiries of authorities.

10. Do I still need an EU authorized representative even if my manufacturer is located in the EU?

Yes, if your company is registered in a third country, you need an EU authorized representative to sell physical products within the European Union. However, having your products produced in the EU has great advantages, e.g., regarding the import because you do not have to declare and pay customs duties on the goods.

11. Why is it important for my products to comply with market requirements in the EU?

Since we and our company are, in a way, also responsible for your products, we accept the role of EU authorized representative only for compliant products. This reduces the risk not only for us, but, more importantly, for you as well. If, for example, your product is ever investigated by a market surveillance authority, you will be well prepared and able to produce all the necessary documents. This way, you can avoid - sometimes very high - fines and/or the destruction of your goods.

12. How does the compliance check of my products work?

For the initial compliance check of your products, you need to provide all the relevant documents to us. This includes the packaging design, instructions, test reports from laboratories and the like. As a matter of course, we can conclude a non-disclosure agreement (NDA) prior to our collaboration, ensuring that all the information shared remains confidential.

13. What happens if my products do not comply with EU market requirements?

If the compliance check reveals any deficiencies regarding the compliance of your products, we can fix them with you in the second step. In the best case, all you have to do is to change your packaging design or do the statutory laboratory tests. In the latter case, you will even benefit from the special prices we negotiated with our partner laboratories. Since we have no economic interest whatsoever in such laboratory tests, you can be sure that we will always focus on the most cost-efficient solution.

14. What are the exact requirements for the product and packaging labeling?

Once the contract has been signed, you can affix the address of our company to the sales packaging of your products in addition to your own company’s address. It is important that both customers and authorities can immediately identify which is the manufacturer and which is the authorized representative. The exact design is explained in detail in the contract.

15. What if I can no longer make changes to my product or packaging?

We'll figure it out together. There are often practical, compliant workarounds. What makes sense will depend on your product, your packaging, and how your distribution is set up. For any future production runs, the required changes will need to be fully incorporated.

16. Do I actually get a German business address for my packaging?

Yes. Even though the registered office of our Product Compliance Service is located in the Republic of Cyprus (the founders of Tradavo have been living on the Mediterranean island for years), we founded a German subsidiary for our EU authorized representative service, which means that you do not have to worry about possible loss of trust on the part of your customers. Furthermore, inquiries from authorities can be delivered and processed by us more quickly this way.

17. What happens in the case of an inquiry from an authority, e.g., a market surveillance authority?

If customs and / or an authority objects to one of your products, e.g., when it is imported into a European country, we will, of course, take care of the entire communications. Whenever our company’s address is indicated, we are always the first point of contact for European authorities. Our communications are always closely coordinated with you, allowing you to stay up to date at all times.

18. How can I be sure that Tradavo fulfills their duties as my authorized representative?

No need to worry. Prior to our collaboration, we conclude a contract under German law that clearly defines our duties as EU authorized representative, among other things. Consequently, you can be absolutely certain that we will not let you down in the case of an inquiry from an authority.

19. Can I start using Tradavo's company address before signing a contract?

No, our address may only be used once a contract is signed and in place. This protects both sides: it ensures that roles, responsibilities, and processes are clearly defined, and that you have the legal certainty you need from day one.

20. Do I have to use UNICON Logistics for my imports from a third country?

No, you are not obligated to import your goods using UNICON Logistics if you commission us as your EU authorized representative. In principle, you are always free to choose your logistics service provider. However, based on our many years’ experience as an e-commerce seller, we can highly recommend UNICON Logistics for your imports. If you still choose to collaborate with another logistics service provider, it is important that they are able to use indirect customs representation for such imports.

How can we assist you and your business?

If you have any more questions, or you are interested in a collaboration with us, please contact us, either by e-mail to service@tradavo.eu, by telephone at +49-177-633-034-0, or by clicking on the button below to schedule an initial consultation via Zoom free of charge. We are looking forward to getting to know your company and your product portfolio.

Tradavo Compliance

My compliance request

Company name incl. legal form
Street, house number, postal code, city, country
Required for invoicing companies with registered office in the EU
Interested in
Examples: Specific need - Name of products - Current status of project - Materials - Amazon ASIN - Links to products.

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