← All terms
CATEGORY: REGULATORY PATHWAYS

Authorized Representative

A legal entity established in a regulatory jurisdiction that acts on behalf of a foreign manufacturer for regulatory purposes. Under EU MDR, non-EU manufacturers must designate an EU Authorized Representative (EC REP). In Japan, this role is filled by the DMAL holder.

Last reviewed 2026-08-05 · Reviewed by MedFlux Editorial Board · Editorial policy

WHEN IT APPLIES

Foreign manufacturers without a legal presence in a market often must appoint a local authorized representative (or equivalent role) to handle registrations, communications, and post-market duties. Under EU MDR this is the EU Authorized Representative (EC REP) for non-EU manufacturers.

PROCESS / STEPS

  1. Confirm whether local establishment is mandatory in the target market (EU, UK, China MAH, Japan DMAL, etc.).
  2. Define contractual responsibilities: registrations, vigilance, competent authority contact, sample availability.
  3. Ensure the representative is qualified and appears correctly on labels / IFU / EUDAMED actor registration.
  4. Align QMS interfaces so complaints and FSCAs flow to the representative within statutory timelines.
  5. Reassess if manufacturing sites, legal manufacturer identity, or markets change.

EXAMPLES

  • EU MDR: non-EU manufacturer designates an EC REP established in the Union.
  • China: foreign sponsors typically work through a Chinese Marketing Authorization Holder (MAH), a related but stricter local-responsibility model.
  • Japan: foreign manufacturers work through a Designated Marketing Authorization Holder (DMAL).

COMMON MISTAKES

  • Appointing a “mailbox” entity that cannot fulfill vigilance or technical documentation duties.
  • Labeling that lists the wrong legal manufacturer vs representative roles.

RELATED GUIDES & TOOLS

SOURCES

Track regulatory signals related to Authorized Representative across 27 authorities in real time.

START FREE →