Resources · EU Machinery Regulation
EU Machinery Regulation 2027 for authorised representatives: mandates, tasks and evidence
An authorised representative does not take over every manufacturer duty. The role is based on a written mandate. That document defines which tasks can and must be performed on the manufacturer's behalf.
A clear mandate also defines product coverage, document access, authority communication and the limits of delegated responsibility.
Use the mandate to make responsibilities, document access and authority requests easier to manage and evidence. Start with the mandate and the specific product. Then organise the work.
On this page
When is an authorised representative appointed?
A manufacturer may appoint an authorised representative established in the Union by written mandate.
The mandate is the basis of the role. Without clear wording, it may be difficult to determine which tasks have been assigned and which remain with the manufacturer.
A useful mandate identifies:
- the manufacturer and the authorised representative;
- the covered products or product families;
- the tasks being delegated;
- its start, duration and relevant changes;
- the documents and access needed to carry out the tasks.
Do not assume that a commercial agent, distributor or local service provider is automatically the authorised representative under the Regulation.
Which manufacturer duties cannot be transferred by mandate?
The Regulation sets limits on delegated tasks.
The manufacturer's duty to ensure machinery or related products are designed and constructed in accordance with the essential health and safety requirements cannot form part of the authorised representative's mandate.
Nor can the manufacturer's duty to draw up the technical documentation under Annex IV.
The authorised representative therefore does not, solely by accepting the mandate, become the person who creates the technical file or makes the manufacturer's underlying technical conformity decisions.
If a proposed mandate appears to transfer these duties, it needs clarification before work begins.
What minimum tasks must the mandate allow?
The written mandate must at least enable the authorised representative to:
- keep the technical documentation and EU declaration of conformity or EU declaration of incorporation available to market-surveillance authorities for at least ten years;
- provide necessary information and documents following a reasoned authority request;
- cooperate with authorities on action to eliminate risks posed by covered products, at their request, within the mandate's scope.
Additional lawful tasks can be included. They need a specific legal basis and clear wording in the mandate.
A practical workflow for authorised representatives
Open the mandate case
Record the manufacturer, representative, affected products and current mandate version. This matters when several manufacturers or product lines are involved.
Review the written mandate
Are both parties clearly identified? Is the product scope clear? Are task descriptions and effective dates understandable? Resolve unclear clauses before relying on them.
Classify tasks and limits
Separate minimum mandate tasks, valid additional tasks and duties that the manufacturer cannot delegate. Do not let routine requests silently expand the mandate.
Organise document availability
Ensure that required declarations and technical documentation can actually be made available to authorities. Define product references, versions, access rights, retention and the manufacturer's document contact.
Manage manufacturer questions and escalation
If a document or technical answer is missing, request it from the manufacturer. Record who must respond, by when, and which task depends on it.
Handle authority requests in a controlled way
Check the authority, deadline, product, requested information and mandate coverage. Supply available documents and seek necessary manufacturer input for matters beyond your own authority.
Control changes and the end of a mandate
A mandate may change or end. Track open authority requests, documents, remaining tasks and handovers. Preserve a clear record of the previous scope and the new arrangement.
Close the case record
A mandate case is closed only when the applicable tasks and evidence are complete or remaining duties have been formally transferred and documented.
Document availability is not a full technical-file review
One of the most important role boundaries is the difference between making a document available and creating or technically approving it.
For each relevant document, record:
- the document type and product reference;
- the current version;
- where and how it can be accessed;
- the manufacturer's technical owner;
- whether access has actually been tested;
- the required availability period.
This gives the representative a reliable route when an authority asks for documents without blurring manufacturer responsibility.
Additional tasks need a clear mandate
The Regulation allows certain tasks to be performed by an authorised representative in specific conformity assessment procedures. It does not make all manufacturer obligations freely transferable.
For an additional task, keep four elements aligned:
Legal basis → mandate clause → applicable product procedure → documented result.
If one part is missing, clarify the task before accepting it.
Requests from market-surveillance authorities
Authority requests are a core practical scenario for authorised representatives.
A useful request record includes:
- requesting authority and contact;
- date received and deadline;
- relevant product and mandate version;
- requested information or documents;
- documents already available;
- outstanding manufacturer input;
- material provided and closure date.
Technical statements outside the mandate or the representative's own competence should be referred to the manufacturer or the responsible specialist.
Cooperation on risk-related measures
Where an authority requires cooperation to address product risks, the authorised representative must act within the written mandate and the Regulation.
This does not authorise independent design changes or the assumption of unassigned manufacturer decisions. The representative coordinates the request and escalates technical measures to the responsible manufacturer.
Keep manufacturer communication visible
Mandate work often depends on timely replies from the manufacturer.
For each open point, record what is needed, who owns the response, its due date, the affected task and the evidence required for closure.
An unanswered request is still open. Keep it visible rather than silently treating it as completed.
Traceability
An authorised representative is an economic operator, but Article 19 identification obligations relate to actual receipt or supply relationships.
Check whether the representative received a product from, or supplied it to, another economic operator in the particular case.
Where no such relationship exists, record why that path does not apply. Do not invent a delivery record merely to fill a form.
Changing or ending a mandate
A new email should not silently overwrite the earlier mandate.
Maintain a version or amendment reference. At the end of the mandate, review outstanding authority questions, required document availability, unresolved manufacturer requests, additional tasks and any handover to a successor or back to the manufacturer.
This supports a clear record of responsibility after the relationship changes.
Common weaknesses in mandate management
- The mandate does not identify the covered products.
- Non-delegable manufacturer duties are assigned in broad wording.
- Access to documentation is promised but never tested.
- Additional work is accepted without checking the mandate and legal basis.
- Manufacturer queries and escalations are not recorded.
- Authority requests are handled outside a case record.
- New mandate versions erase earlier tasks and decisions.
- The mandate ends without closing or transferring open obligations.
Four questions for the authorised representative role
The answers give you a clear view of delegated tasks, available documents and outstanding requests to the manufacturer.
What does our mandate cover?
Confirm the manufacturer, products, period and assigned tasks.
What are we allowed and required to do?
Identify mandatory and additional delegated tasks, and exclude duties that legally remain with the manufacturer.
How do we manage the work?
Use a mandate record, document-access controls, manufacturer requests, deadlines and escalation paths.
How do we evidence completion?
Keep current mandates, document availability records, authority correspondence, decisions, handovers and the final case status.
Practice Kit for authorised representatives
SP Services is developing an English-language Authorised Representative Practice Kit with prepared mandate, task and evidence structures. Use them to organise delegated work, track document requests and keep authority correspondence linked to the right product and mandate – rather than building each case file from scratch.
The kit supports documentation; it does not transfer non-delegable manufacturer duties or guarantee conformity.
Individual support
Complex mandates and manufacturer interfaces can benefit from a clearer operating structure.
SP Services can support task definition, document and communication workflows, authority-response coordination and project structure within an agreed scope.
Frequently asked questions
Can an authorised representative create the manufacturer's technical documentation?
Not as a transferred duty under the mandate. The manufacturer's duty to draw up the Annex IV technical documentation cannot be delegated under Article 12.
Must the authorised representative be established in the EU?
Yes. The Regulation defines the authorised representative as established within the Union.
Does the appointment need to be in writing?
Yes. The role is based on a written mandate from the manufacturer.
How long must documents remain available to authorities?
The mandate must allow the required technical documentation and declaration to be kept available for at least ten years, as specified in the Regulation.
Can the mandate include additional tasks?
Yes, where the law permits and the tasks are clearly covered. Non-delegable manufacturer duties remain excluded.
Sources and editorial date
Editorial review: 16 October 2026
Legal source edition: Regulation (EU) 2023/1230, consolidated 27 July 2026.
- EUR-Lex — Machinery Regulation (EU) 2023/1230, especially Articles 12, 17–19 and relevant conformity assessment provisions
- European Commission — Machinery
- BAuA — Machinery Directive revision
Note: This is general regulatory and technical information. It is not legal advice, technical-file approval, certification or confirmation that a particular machine complies.
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