Registering products in EPREL is the pre-condition required under EU law before placing products on the Union market. The same requirement applies to products placed on Northern Ireland market that can then be freely distributed in the Union.
Registration in EPREL of products manufactured by a third-country company can only be done by economic operators established in the Union: either the importer (s) or an authorized representative fulfilling the conditions to act as such.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.