Do I Need an Authorized Representative for EUDR if Based Outside the EU?

• EUDR Article 6 allows non-EU operators to appoint an EU-based authorized representative.
• The representative submits due diligence statements but does not assume liability.
• Medium/large operators: obligations from 30 Dec 2026; micro/small: 30 Jun 2027.
• Appointment is by written mandate; operator remains responsible for compliance.
• Not all companies need this—downstream buyers often do not file statements.

Updated 20 October 2026 · 14 sources checked

Providers compared

Prices as published on each provider's website on 20 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires: Article 6 EUDR and Who Must Appoint a Representative

Regulation (EU) 2023/1115 (EUDR), as amended by 2025/2650, aims to ensure that certain commodities and derived products placed on or exported from the EU market are deforestation-free. Article 6 specifically allows non-EU operators and traders to appoint an authorized representative established within the EU to file due diligence statements (DDS) on their behalf. This is not a legal obligation but an option, designed to help non-EU companies meet their filing requirements when they lack an EU presence.

• Who must file DDS? The obligation falls on primary operators and exporters—those who first place a covered commodity on the EU market or export it from the EU. Downstream operators (those buying from other downstream operators) are, since the 2025 amendment, generally outside the obligation to file DDS. Instead, they must keep and pass on the reference number of the primary operator's statement.
• What is covered? The EUDR applies to seven core commodities: cattle, cocoa, coffee, oil palm, rubber, soya, and wood, as well as a wide range of derived products. The exact scope is defined in Annex I of the regulation.
• Key dates: Medium and large operators and traders must comply from 30 December 2026. Micro and small enterprises have until 30 June 2027. The cut-off date for deforestation-free status is 31 December 2020, which has never changed.
• Liability: Appointing an authorized representative does not transfer legal responsibility. The operator or trader remains fully liable for the accuracy and completeness of the information submitted.
• Record keeping: All operators and traders must retain relevant documentation for at least five years, regardless of whether a representative is used.

In summary, appointing an authorized representative is a practical option for non-EU companies that need to file DDS, but it is not mandatory. The operator remains responsible for compliance and for any penalties in case of non-compliance.

How to Choose an EUDR Authorized Representative

Choosing the right EUDR authorized representative (AR) is crucial for efficient compliance. Not all providers offer the same scope of service, and many focus on other regulations (such as GPSR) rather than EUDR-specific filings. Here are practical steps and considerations:

• Coverage: Ensure the AR covers all EU/EEA countries relevant to your supply chain. Some providers, like REP27, cover the entire EEA, while others may be limited to specific countries or regulations.
• Experience: Check if the provider has a track record with EUDR filings, not just GPSR or other AR mandates. EUDR is a new and evolving area, so up-to-date expertise is essential.
• Scope of service: Does the provider handle only the filing, or also correspondence with authorities, record retention, and support for regulatory changes? Some, like glebora and Pier Compliance OÜ, offer due diligence support or eligibility assessments, while others do not.
• Language and documentation: Multilingual support (e.g., privacy wording in 8 languages from REP27) can be valuable for international supply chains.
• Transparency and pricing: Confirm what is included in the published price. Some providers charge per product, per filing, or for additional services such as document translation or regulatory updates. Always request a full breakdown.

Decision matrix:

In practice, always clarify your position in the supply chain before engaging a provider. Many companies discover, after the 2025 amendment, that they do not need to file DDS or appoint an AR at all.

What the Price Really Includes: Provider Comparison

Provider pricing for EUDR authorized representative services varies widely, and the published price often covers only part of the compliance journey. Many providers are focused on GPSR (General Product Safety Regulation) AR services, which are not interchangeable with EUDR AR services. Some, like REP27, offer EUDR-specific mandate management, while others (e.g., Westwood Sourcing, AuraDPP, GPSR Solutions) target GPSR or general AR needs.

Below is a comparison of what is included, not included, or may incur extra fees for each provider (based on available data):

Key points to verify before signing:

• Does the price include all filings, or is it per statement/product?
• Are authority correspondence and record retention included?
• Is there support for regulatory changes or language localization?
• Are there additional fees for document translation, urgent filings, or extra services?

Always request a detailed service description and written confirmation of all inclusions and exclusions.

Hidden Costs and Exclusions

While headline prices for EUDR AR services may seem clear, hidden costs and exclusions are common. Providers may charge additional fees for extra filings, document translation, regulatory updates, or support beyond the basic mandate. Some services are limited to a certain number of products, filings, or requests, and exceeding these limits can incur significant extra costs.

• Due diligence work: Most ARs, including REP27, do not perform the actual due diligence (e.g., collecting geolocation data, risk assessment, mitigation). This remains the operator's responsibility.
• Liability: No provider, based on available data, assumes legal liability for compliance. The operator is always responsible for the accuracy and completeness of the DDS.
• Notice periods and termination: These are rarely detailed upfront. Always check the contract for minimum commitment periods and termination notice requirements.
• Per-request or per-filing fees: Some providers may charge for each additional filing or request beyond the base package. Confirm whether the quoted price is all-inclusive.
• Language and translation: Multilingual support may be limited or incur extra charges.

Summary table of typical inclusions/exclusions:

Always clarify these points in writing before signing any agreement.

How Appointment Works: Step by Step

Appointing an EUDR authorized representative is a structured process. Here is a practical, step-by-step guide based on current legal and market practice:

1. Assess your status: Determine if you are a primary operator or exporter for EUDR-regulated commodities. If you are only a downstream operator buying from another downstream operator, you likely do not need to file DDS or appoint an AR.
2. Map your supply chain: Identify all suppliers and confirm if you are the first to place the commodity on the EU market.
3. Gather documentation: Collect all required due diligence data: geolocation of production plots, evidence of legality, risk assessment, and mitigation measures. This is the most time-consuming part.
4. Select a provider: Compare AR providers based on coverage, experience, included services, and pricing. Request detailed quotes and clarify all terms.
5. Sign a written mandate: The mandate must clearly authorize the AR to act in the EU Information System (TRACES) on your behalf. Both parties must be registered in the system under their respective roles.
6. Submit documentation: Provide the AR with all required data. The AR will file the DDS, return the reference number, and handle authority correspondence.
7. Retain records: Maintain all documentation for at least five years, as required by EUDR.

Checklist to follow today:

1. Confirm your company’s EUDR status (primary operator, exporter, downstream, etc.).
2. Identify all covered commodities and derived products in your supply chain.
3. Collect required due diligence documentation.
4. Shortlist AR providers and request detailed service descriptions.
5. Negotiate and sign a written mandate with your chosen provider.
6. Submit due diligence data for filing.
7. Monitor compliance deadlines: 30 Dec 2026 (medium/large) or 30 Jun 2027 (micro/small).

Timely preparation is critical, especially for companies with complex supply chains or large product portfolios.

Risks, Fines, and What Providers Usually Do Not Say

Non-compliance with EUDR can result in significant penalties, including fines set by Member States, confiscation of goods, and exclusion from public procurement. The operator or trader is always legally responsible, even if an AR files the DDS on their behalf. Providers rarely highlight these risks or their own service limitations.

• Liability remains with you: The AR does not assume legal responsibility for compliance. If the DDS is incomplete or inaccurate, the operator is liable for any enforcement action.
• Fines: Penalties are set by each Member State and are proportionate to environmental harm and the value of the goods. There is no fixed EU-wide fine for EUDR breaches.
• Record keeping: Failure to retain documentation for five years can itself be a compliance breach.
• Due diligence is yours: No AR can perform the actual due diligence, as it relies on your supply chain data and risk assessment. Providers may assist with filing, but not with the underlying work.
• Notice periods and extra fees: Many providers do not disclose minimum contract terms, notice periods, or per-request charges upfront. Always check the contract.
• Reference number is not a certificate: The DDS reference number shows a statement was filed, not that an authority has verified compliance.

What providers usually do not say:

• They do not take on legal risk or pay fines for you.
• They may charge extra for each additional filing, product, or request.
• Some only cover GPSR, not EUDR-specific filings.
• Termination and renewal terms may be restrictive.

Always read the service agreement carefully and confirm all terms in writing before proceeding.

Realistic Scenarios: Who Needs What?

• US SaaS company selling software only: EUDR does not apply. The regulation covers only physical commodities and certain derived products. No AR or DDS filing is needed.
• Chinese Amazon seller exporting wood furniture: If the seller is the primary operator (i.e., first to place the product on the EU market), they must file a DDS and may appoint an EU AR to handle filings and correspondence. If Amazon is the operator (e.g., for FBA), the seller may not need to file or appoint an AR. Always check the marketplace’s compliance stance.
• UK online shop reselling EU-imported coffee: If buying from an EU distributor (downstream operator), the UK shop is outside the DDS filing obligation after the 2025 amendment. No AR is needed. If importing directly from origin, the shop is a primary operator and must file DDS (and may appoint an AR).
• Brazilian rubber exporter: As a primary exporter to the EU, must file DDS for each shipment and may appoint an AR for filings and correspondence. All due diligence (geolocation, legality, risk assessment) must be completed before filing.
• Small Vietnamese cocoa cooperative: If classified as a micro or small enterprise in a low-risk country, may be eligible for a one-off simplified declaration. Ongoing AR appointment may not be necessary unless desired for convenience.

These scenarios illustrate the importance of mapping your supply chain and understanding your exact obligations before engaging an AR provider.