Can a UK distributor rely on an EU representative whose mandate does not cover UK duties?

Can a UK distributor rely on an EU representative whose mandate does not cover UK duties?

For electrical equipment, regulation 14(1) of the Electrical Equipment (Safety) Regulations 2016, SI 2016/1101, states: “A manufacturer may, by written mandate, appoint a person established in the United Kingdom as their authorised representative to perform specified tasks on the manufacturer’s behalf.”

The company does not say whether any representative's mandate covers those tasks. The company sets out its position under two bodies of law only, and neither of them is the law there.

Under United States law, NF Technical Products Inc. classifies the NanoFlashing™ Air Filter as a device under Section 2(h) of the Federal Insecticide, Fungicide, and Rodenticide Act, 7 U.S.C. § 136(h), and 40 C.F.R. § 152.500(a). Under Regulation (EU) No 528/2012, C-POLAR Technologies, Inc. classifies the same filter as neither a biocidal product nor a treated article. Each statement records that it addresses that one question only. No authority has approved, registered, endorsed or cleared the filter; the company classifies its own article.

What an authority requires of a product placed on its market is decided under its own rules, by the party that places it there. Every commercial NanoFlashing™ product is made by a manufacturing partner, in their facility, in their format.

Source: Statement of Classification for the NanoFlashing™ Air Filter, sections 1.3 and 3.7, issued by NF Technical Products Inc.; Statement of Regulatory Status for the NanoFlashing™ Air Filter, sections 1.3 and 3.7, C-POLAR Technologies, Inc., 11 September 2026; C-POLAR — Terms of Use, section 6, https://cpolar.tech/terms/; Electrical Equipment (Safety) Regulations 2016, SI 2016/1101, regulation 14, read 20 September 2026, https://www.legislation.gov.uk/uksi/2016/1101/regulation/14.

Reviewed on 21 September 2026.