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Do EU/EEA manufacturers also need a CH-REP to sell in Switzerland?
I'm an EU manufacturer with CE marking under MDR/IVDR. I assumed I wouldn't need a CH-REP since Switzerland is similar to the EU, but I'm hearing conflicting information. Do EU manufacturers really need a Swiss Authorized Representative?
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Asked by Lo H. Khamis
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Lo H. Khamis, Regulatory Experts
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## Do EU/EEA Manufacturers Need a CH-REP?
**Yes—EU/EEA manufacturers absolutely need a CH-REP to sell in Switzerland**, even though they may already have CE marking under EU MDR/IVDR.
### Why This Surprises People
Many EU manufacturers assume that because:
- Switzerland has similar regulations to the EU (MedDO aligns with MDR, IvDO aligns with IVDR)
- They already have CE marking and an EU Authorized Representative
- The regulatory frameworks are harmonized
...they don't need a separate Swiss representative. However, this is a common misconception.
### The Reality: Switzerland's Independent Market Access Requirements
Switzerland treats **all manufacturers not established in Switzerland as "foreign"** for regulatory purposes, regardless of whether they're from the EU/EEA or elsewhere. According to Swissmedic's economic-operators guidance, the CH-REP requirement applies to manufacturers established in the EU/EEA just as it does to manufacturers from other countries.
### What This Means for EU Manufacturers
For EU manufacturers, entering the Swiss market becomes:
1. **A packaging and labeling exercise** - You'll need to add CH-REP information to your labels, packaging, and IFU
2. **A contract and mandate exercise** - You must establish a written mandate with a Swiss-based CH-REP
3. **A registration exercise** - The CH-REP (and potentially you as importer) must register for CHRN
4. **A vigilance coordination exercise** - You'll need to ensure Swiss-specific reporting flows are established
**Your CE conformity work remains central** - you don't need to re-certify your devices, but you must establish the Swiss economic-operator chain.
### Key Distinction
- **EU-REP**: Required for EU/EEA market access (handles EU MDR/IVDR compliance)
- **CH-REP**: Required for Swiss market access (handles Swiss MedDO/IvDO compliance)
These are separate roles that cannot be combined, even though the underlying regulations are similar.
### Next Steps
1. **[Compare Swiss CH-REP providers & request quotes](https://cruxi.ai/regulatory-directories/ch_rep)** - Use our directory to find and compare qualified CH-REP providers
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*Written by **Lo H. Khamis**, Regulatory Experts. [Connect on LinkedIn](https://www.linkedin.com/in/lo-h-khamis) for regulatory guidance.*
### Official Sources:
- [Swissmedic - Economic Operators Guidance](https://www.swissmedic.ch/swissmedic/en/home/medical-devices/economic-operators.html)