Is an Authorized EUDR Representative Required for Non-EU Traders?

• The obligation depends on your role in the supply chain and company size (Art. 6 EUDR)
• From 30/12/2026 for medium and large companies, from 30/06/2027 for micro/small companies
• The representative submits declarations but does not assume responsibility
• Many downstream operators have no obligations after the amendment
• REP27 — Europe Services, SE offers designation within 24h, price on request

Updated 23 October 2026 · 10 sources checked

Providers compared

Prices as published on each provider's website on 23 October 2026, excluding VAT unless stated. Each row links to its source.

What the EUDR Law Requires (Art. 6 and 2025/2650)

Regulation (EU) 2023/1115, amended by Regulation 2025/2650, governs the obligation to appoint an authorized representative for non-EU operators and traders placing products derived from seven key commodities (such as cocoa, coffee, soy, palm oil, cattle, timber, rubber) on the European market. Article 6 allows appointing a representative established in the Union to submit due diligence declarations in the European IT system.

The 2025/2650 amendment revolutionized the scope of the obligation: most downstream operators, i.e., those purchasing from other downstream operators, no longer need to submit declarations or appoint a representative. The obligation remains for primary operators (those first placing the product on the EU market) and non-EU exporters. Deadlines are set for 30 December 2026 for medium and large companies and 30 June 2027 for micro and small companies. Compliance responsibility always remains with the operator or exporter, even after appointing the representative.

The representative can submit the due diligence declaration, receive correspondence from authorities, and retain documentation for five years but cannot perform due diligence or assume responsibility for errors or omissions in the provided data.

The regulation requires all declarations to be accompanied by geolocation data of plantations, proof of legality, and risk assessment. The representative, if appointed, acts as a contact point and is responsible for submitting declarations but cannot replace the company in data collection and risk evaluation activities.

How to Choose an EUDR Representative: Practical Criteria

Choosing an EUDR representative is crucial for those obligated by the regulation. Here are the main practical criteria to follow:

• Role in the supply chain: Only primary operators and non-EU exporters must appoint a representative. If you are a downstream operator purchasing from other downstream operators, you have no obligations.
• Company size and deadlines: Deadlines vary by size: medium/large companies from 30/12/2026, micro/small from 30/06/2027.
• Included services: Verify that the provider offers submission of EUDR Art. 6 declarations, handling authority requests, and document retention for 5 years. Many providers offer only GPSR services, not EUDR.
• Transparency and clarity: Always request written confirmation that the service covers EUDR and not only other regulations.
• Geographical coverage: A representative established in any EU Member State is valid throughout the Union.

The main risk is purchasing a service that does not cover EUDR: most providers in the table publish prices only for GPSR (General Product Safety Regulation) and do not specify EUDR service. REP27 — Europe Services, SE explicitly declares EUDR Art. 6 coverage, though the price is on request.

Practical tip: before purchasing, send a written inquiry and ask for formal confirmation that the service covers submission of EUDR Art. 6 declarations.

What Does the Price Really Include? Detailed Comparison Table

Many providers publish prices only for GPSR representative services, not for EUDR. Here is a table summarizing what is included, what is not, and possible extra costs (where stated):

Most providers do not specify if EUDR service is included in the published price. Always ask for detailed written confirmation. REP27's service includes designation, submission of EUDR declarations, authority correspondence management, and document retention for five years. No provider, including REP27, assumes liability for due diligence or data compliance.

Hidden Costs, Limits, and Practical Risks

When choosing an EUDR representative, it is crucial to understand service limits and possible hidden costs. Here is what the available data reveals:

• Liability: No provider assumes legal liability for errors or omissions in provided data. Responsibility always remains with the operator or exporter.
• Due diligence: Data collection, geolocation, risk assessment, and mitigation are always the company's responsibility. The representative only transmits declarations and retains documents.
• Extra costs: Providers do not declare specific extra costs for EUDR. However, many publish prices only for GPSR. For EUDR, the price is often "On request" and may vary based on volume, complexity, and additional services requested.
• Service limitations: Some providers may limit the number of products, handled requests, or supported languages, but this information is not always published.
• Notifications and correspondence: REP27 guarantees forwarding authority requests on the same working day but does not handle substantive responses.

Practical risks: If you purchase a GPSR-only service thinking it covers EUDR, you risk non-compliance. Also, appointing a representative does not exempt you from penalties for incorrect or incomplete data.

Tip: always request a detailed list of included and excluded services and check any notice periods for termination.

How the Representative Appointment Works: Step-by-Step Guide

1. Identify your role in the supply chain: Are you a primary operator, exporter, or downstream operator?
2. Check if you have declaration obligations: After amendment 2025/2650, only primary operators and non-EU exporters must submit EUDR declarations.
3. Gather due diligence data: Geolocation of plantations, proof of legality, risk assessment, and any mitigation.
4. If necessary, choose a provider offering EUDR Art. 6 representation: Verify the service includes declaration submission and correspondence management.
5. Sign the representation mandate: The provider will supply a document to sign, often electronically.
6. The representative submits the declaration in the EUDR system: You will receive a reference number to include in your commercial documents.
7. Keep documentation: All data and declarations must be retained for at least 5 years.

This process also applies if you choose to appoint a representative before the mandatory deadline, for operational convenience. However, appointment is premature if you have not yet collected all due diligence data: the EUDR declaration is the final step of a process starting from the field.

Risks, Sanctions, and What Authorities Check

EUDR regulation provides significant sanctions for non-compliance. Here's what to know:

• Liability: Even with a representative, responsibility always remains with the operator or exporter. If data is incorrect or incomplete, sanctions affect the company, not the representative.
• Sanctions: Member States set sanctions based on product value and environmental damage. These may include fines, goods confiscation, and exclusion from public procurement.
• Checks: Authorities verify declaration accuracy, presence of geolocation data, legality documentation, and risk assessment. They request supporting documents for the declaration.
• Retention period: All documentation must be kept for at least 5 years and made available to authorities upon request.

The greatest risk is non-compliance due to errors in data collection or misidentifying your role in the supply chain. An error in assessment can lead to sanctions even if you have appointed a representative.

Tip: regularly update your risk assessment and ensure all documentation is always ready for possible inspections.

Decision Matrix: Who Really Needs an EUDR Representative?

This matrix helps you understand if you must appoint an authorized EUDR representative:

The key is correctly identifying your role. If you are a downstream operator purchasing only from other downstream operators, you have no EUDR obligations after the amendment. If you are the first entity placing the product on the EU market or export directly, the obligation applies and appointing a representative is necessary.

Practical Checklist for EUDR Compliance

1. Identify your role in the supply chain (primary operator, exporter, downstream operator).
2. Check if your company is subject to declaration obligation after amendment 2025/2650.
3. Gather all due diligence data: geolocation, proof of legality, risk assessment, and mitigation.
4. If obligated, choose a provider offering EUDR Art. 6 representation (request written confirmation).
5. Sign the representation mandate with the chosen provider.
6. Have the declaration submitted in the EUDR system and obtain the reference number.
7. Include the reference number in commercial documentation.
8. Retain all documentation and declarations for at least 5 years.
9. Prepare an internal procedure to respond quickly to authority requests.
10. Periodically review your supply chain position and update due diligence if suppliers or products change.

Following this checklist reduces the risk of errors and sanctions and allows you to demonstrate compliance during inspections.

What Providers Often Don’t Say (and What to Always Ask)

• Appointment does not transfer liability: Even with a representative, the operator remains responsible for all obligations and sanctions.
• Due diligence always company’s responsibility: No provider can collect geolocation data, assess risk, or mitigate it on your behalf.
• Services often advertised only for GPSR: Many providers publish prices and details only for GPSR representation, not EUDR. Always ask for written confirmation that the service covers EUDR Art. 6.
• Extra costs and limits: EUDR prices are often "On request" and may vary. Check for limits on products, requests, or languages.
• Notifications and response times: Some providers guarantee only forwarding authority requests, not substantive responses.
• Termination and notice: Cancellation terms are not always published. Always ask about notice periods and procedures.

Tip: request a copy of the contract before signing and verify every clause on liability, limits, and included services.

Three Real Scenarios: What to Do in Practice

• US SaaS collecting EU user data: Not subject to EUDR but may need to appoint a GDPR Art. 27 representative (see GDPR guide). No EUDR obligation if not handling covered commodities.
• Chinese seller on Amazon EU: If directly importing and first placing EUDR products on the EU market (e.g., coffee, cocoa, timber), they are a primary operator and must appoint a representative. If purchasing from EU distributors (downstream), no obligation after the amendment.
• UK online shop exporting coffee to EU: If directly importing into the EU, they are a primary operator and must appoint a representative. If purchasing from EU distributors, no obligation. If exporting EUDR products from the EU, they must still submit declarations.

These scenarios show how supply chain position and product type determine the obligation. Always verify your role and product nature before purchasing a service.