CE test reports alone don’t make you compliant in the EU or UK. In this episode, Sofeast CEO and host Renaud is joined by Roberth Jonsson Co-Founder of 24HourAR, to unpack who is legally the “manufacturer,” when you need a Responsible Person or Authorized Representative, and how GPSR, ESPR/Digital Product Passports, and the new Product Liability rules are tightening enforcement for importers and private-label brands.
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What you’ll learn in this episode
- Why CE test reports ≠ full compliance (technical file, risk assessment, DoC, labeling, manuals).
- Who is legally the “manufacturer” in the EU/UK (hint: private-label importers usually are).
- When you must name a Responsible Person (often an Authorized Representative) and where it appears on the product/pack.
- How GPSR, ESPR/Digital Product Passports, and Product Liability changes raise the bar for sellers into the EU.
- Practical ways to avoid shipments being blocked by customs for missing documentation or contact details.
Episode Sections:
- 00:00:13 – Introduction.
- 00:03:20 – EU compliance at a high level: directives vs standards; CE ≠ everything.
- 00:06:51 – Who’s the “manufacturer” legally? Private label importers beware.
- 00:10:16 – Testing reports vs full compliance: technical file, risk assessment, manuals.
- 00:12:26 – The “responsible person” & why it exists.
- 00:14:18 – Market Surveillance Reg (2019/1020) and GPSR expanding the scope.
- 00:17:41 – Importer obligations & the pain of sharing technical docs with many importers.
- 00:20:03 – When to appoint an Authorized Representative (AR); DTC and online sellers.
- 00:23:17 – Dropshipping into the EU: why customs may block you without an EU RP.
- 00:25:15 – EU vs UK: similar rules, separate markets; you need separate reps.
- 00:26:22 – “Can my cousin be the AR?” Contracts, duties, and… big risks.
- 00:27:13 – Coming change: Product Liability Directive will add AR liability.
- 00:29:19 – ESPR & Digital Product Passports; unified customs tools = tighter checks.
- 00:33:05 – Gatekeepers: ARs/importers get pickier as liability rises.
- 00:34:44 – How to contact 24HourAR.
Extra resources to dive deeper
- CE Compliance for Manufacturing in Asia: A Beginner’s Guide
- 11 Common Electronic Product Certification And Compliance Requirements
- What is the EU Ecodesign for Sustainable Products Regulation?
- 7 Upcoming EU Product Compliance Requirements (as of 2023)
- New EU MDR: Who Are The “Economic Operators” For Imported Devices?
- We’re Buying Medical Devices From China And Are Worried Our Supplier Isn’t Legit | Disputes With Chinese Suppliers Q&A (Volume 8)
- Check out https://www.24hour-ar.com/ and learn about Roberth
- Get help from Sofeast (quality, NPD, manufacturing, audits, inspections): https://www.sofeast.com/
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