EU Authorised Representative

For product conformity and the EU DPP Registry — not extended producer responsibility.
SENSONEO j. s. a. is a verified economic operator in the EU DPP Registry and acts as authorised representative for manufacturers established outside the Union. A manufacturer established outside the EU cannot become a verified economic operator in the EU DPP Registry: the qualified seal that verification requires is issued to EU legal entities, and the operator identifier is an EU one. Someone established in the EU has to carry that identity for you: an EU importer, or an authorised representative appointed under a written mandate. This page is about what that role actually is.

Why you cannot do it yourself

Not a platform limitation — a legal one. EU qualified trust service providers issue seals to EU legal persons, and the Registry identifies operators by EU identifiers such as EORI. A seal from outside the EU will not validate.

What an authorised representative does

Acts for you on the EU market under a written mandate: holds the verified identity in the Registry, carries the obligations that attach to the responsible operator, and is the address authorities turn to.

What you still own

The product data. Materials, carbon footprint, recycled content, substances, documents — that is your technical documentation, and nobody else can author it. You bring it in whatever shape you have it.

Don’t have one yet?

Then talk to us — we can be it. As your authorised representative we take on EU Login, enrolment, the sealed declaration, verification and the assignment that lets passports be published, and we host the passports themselves as your DPP service provider. One agreement covers both.

Talk to us →

One agreement, not three

Instead of finding an EU entity, a platform and someone to do the registry paperwork separately, it is one contract and one point of contact in Europe.

Already have an EU importer?

Then you may not need us for this at all. Your importer can hold the verified status and authorise us purely as the DPP service provider — we will tell you which is cheaper for your setup.

What we are, and what we are not

The roles around a passport are confused with one another constantly. Two of them are ours; the rest are not. This is the line, in the same words we put in the contract.

We are your authorised representative

Appointed under a written mandate under Article 40 of the Battery Regulation, and under the delegated act covering your product group. We hold the verified operator identity in the Registry, register your passports, keep your declaration of conformity and technical documentation at the authorities’ disposal for ten years, and are the address market surveillance authorities write to.

We are not a producer responsibility organisation

A PRO collects contributions from producers and organises the collection, treatment and recycling of waste. We do none of that. The EPR authorised representative under Article 56(3), registration in national producer registers and recycling contributions are a different role under different rules, and we do not take it.

And we are not your importer

We are not importer of record, we do not clear customs, and we do not assess, test or certify your products. Drawing up your technical documentation stays with you — Article 40(2) does not allow it to be delegated to a representative at all.

If you need a producer responsibility organisation as well, we will introduce you to one in each Member State concerned. That is a separate contract between you and them.