GPSR compliance series. This article is the EC REP certificate and the authorised representative role. Start at the hub: What GPSR Actually Is: The General Product Safety Regulation Explained.
Since December 13, 2024, Your Luggage Needs an Address in Europe
That's the day the EU's General Product Safety Regulation — GPSR, Regulation (EU) 2023/988 — started applying. And its demand is simple to state: products sold to EU consumers must be traceable to an economic operator established in the EU.
For a manufacturer outside the EU, like a luggage factory in China, that operator can be an importer, a fulfilment service provider, or an authorized representative. CLK's answer is the third option: Jiangxi Chengleke Leather Co., Ltd has appointed EUREPSTAR GmbH of Ingolstadt, Germany, under agreement number EUREP-2025082911400605716, valid from September 19, 2025 to September 18, 2027.
The EC REP certificate documents that appointment — and it carries one condition that matters: CLK must maintain the CE certificates, updated technical files and Declarations of Conformity for its products in the EU market. The appointment gives EU authorities and buyers a real person and address to reach. That's the practical backbone of GPSR compliance.
Why GPSR Created the "欧代" Role
Buyers from China often just call it 欧代 — the EU representative. Under GPSR, the role exists because a product with no reachable EU entity is, from a regulator's view, a product that can't be recalled, inspected, or answered for.
So the regulation requires that EU economic operator. For a Chinese manufacturer, the EC REP certificate is the document that proves the authorized-representative route is in place.
The Certificate, Read in One Minute
| Certificate element | Value |
| Appointing party | Jiangxi Chengleke Leather Co., Ltd (江西诚乐可皮具有限责任公司) |
| Authorized representative | EUREPSTAR GmbH, Ingolstadt, Germany |
| Agreement number | EUREP-2025082911400605716 |
| Validity | Sep 19, 2025 - Sep 18, 2027 |
| Condition | CE certificates, technical files and DoCs kept current |
| Responsibility | CLK remains responsible for EU-market product disputes |
What the Appointment Does
The authorized representative acts as the EU point of contact for the manufacturer:
- EU authorities can reach a real entity in the EU about CLK's products.
- The representative holds or can access the manufacturer's contact information and documentation.
- Buyers and marketplaces see an EU address on the product documentation.
One thing the appointment does not do: move legal responsibility to the representative. The certificate says it plainly — CLK remains responsible for any business dispute related to its products in the EU market.
What This Certificate Does NOT Mean
Honest boundaries, because they get blurred all the time:
- It is not a product certificate. It does not test the luggage; it documents the EU representation behind the products.
- It does not replace CE. The appointment is conditional on CLK maintaining CE certificates, technical files and DoCs — the evidence side stays in place.
- It is time-limited. The agreement runs to September 18, 2027 and must be renewed.
- It does not transfer liability. CLK stays responsible for product disputes in the EU.
From Our Side of the Factory
When a buyer asks "what is the EC REP for?", the honest answer we give is: it is the EU address that GPSR requires behind our products. And it only works if the technical documents behind it are current, which is why the certificate makes CE documentation a condition of the appointment.
We keep the two together in the folder we share — the address and the evidence. One without the other is a compliance gap wearing a certificate.
Frequently Asked Questions
What is an EU authorized representative (欧代)?
An economic operator established in the EU that a non-EU manufacturer designates as its point of contact, as required by GPSR and related EU frameworks.
Why does CLK have a German representative?
Because CLK sells products into the EU from outside the Union, and GPSR requires an EU-established economic operator behind those products. EUREPSTAR GmbH fills that role.
Is this certificate a product safety test?
No — it documents the authorized-representative appointment. Product safety evidence comes from the test reports and CE documents (our other certification articles).
Who is responsible if a product has a problem in the EU?
The certificate is explicit: the manufacturer (CLK) remains responsible for business disputes related to its products. The representative is the EU point of contact, not the liability holder.
How long is the appointment valid?
From September 19, 2025 to September 18, 2027 — two years. Renewal keeps the representation current.
Do buyers need their own EU representative?
It comes down to who places the product on the EU market. If your brand is the EU economic operator for goods it imports, GPSR obligations apply to your placement - Article K3 explains the split.
About the Author
Written by the CLK Manufacturing Team — 16+ years of custom luggage OEM/ODM experience from our factory in Ji'an, Jiangxi, China. Updated: 2026-08-15.
Related Products & Sourcing
CLK Luggage (Jiangxi Chengleke Leather Co., Ltd.) manufactures custom hard-shell luggage, aluminum-magnesium cases and luggage sets for brands, retailers and corporate clients. Relevant resources:
- Browse our luggage sets and custom OEM/ODM luggage manufacturing
- Why choose CLK — factory profile, quality control and certifications
- Get a quote: contact our team or email clkbusiness@clkluggage.com