EUDR Authorised Representative for Operators Outside the EU: Providers & Prices (2026)
- Article 6 EUDR allows non-EU operators to mandate an EU-based authorised representative.
- REP27 — Europe Services, SE: EUR 290–890/year, designation in 24 hours.
- EUDR Vault: £49/month; InvariTech: price on request.
- Mandate covers filing and correspondence, not due diligence or liability.
- Many downstream operators and small enterprises do not need to file after the 2025 amendment.
- Operators remain fully liable for compliance, even with a representative.
Providers compared
| Provider | Established in | Published price | What the price includes | Best for |
|---|---|---|---|---|
| REP27 — Europe Services, SE | Czech Republic | EUR 290–890/year | Signed mandate, statement filing, reference numbers, correspondence, 5-year document holding; does not do due diligence or assume liability. | Primary operators/exporters needing EUDR filing in 2026–2027 |
| EUDR Vaultsource | United Kingdom | £49/month | Up to 5 suppliers, 50 shipments/month, 10 due diligence statements/month, evidence storage, audit trail, regulatory digest, email support. | Operators with moderate EUDR filing and evidence storage needs |
| InvariTechsource | European Union | On request | Due diligence statement submission, compliance support, risk assessment assistance, documentation, scalable for growth. | Operators seeking broader compliance support |
Prices as published on each provider's website on 16 October 2026, excluding VAT unless stated. Each row links to its source.
What the Law Requires: EUDR Article 6, Scope, and Key Dates
Regulation (EU) 2023/1115 (EUDR), as amended by 2025/2650, aims to prevent deforestation by requiring operators and traders placing relevant commodities on the EU market (or exporting from the EU) to submit due diligence statements. Article 6 allows non-EU operators and traders to appoint an authorised representative established in the Union to file these statements on their behalf. This is a procedural convenience, not a transfer of legal responsibility: the operator remains liable for compliance, including the accuracy of geolocation data and legality evidence.
Key dates:
- Medium and large operators and traders: compliance required from 30 December 2026
- Micro and small enterprises: compliance required from 30 June 2027
The regulation covers seven core commodities: cattle, cocoa, coffee, oil palm, rubber, soya, and wood, as well as derived products (see Annex I). The 2025 amendment clarified that most downstream operators are now exempt from filing their own statements; only primary operators and exporters must file. Micro and small primary operators in low-risk countries may submit a one-off simplified declaration.
Operators and traders must keep all records for at least five years. The EUDR defines 'deforestation-free' as commodities produced on land not deforested after 31 December 2020. The Information System is the official EU platform for submitting due diligence statements and receiving reference numbers, which travel down the supply chain.
Legal references: Article 6 EUDR (mandate), Article 4 (due diligence), Article 8–11 (statement content), Annex I (scope), Regulation (EU) 2025/2650 (amendments).
How to Choose an EUDR Authorised Representative
Choosing an EUDR authorised representative is primarily about compliance, reliability, and transparency. The representative must be established in an EU Member State and must accept a written mandate. Key considerations include:
- Location: Only EU-based entities can act as authorised representatives. UK-based companies must have an EU entity.
- Scope of service: Some providers (e.g., REP27) focus on procedural filing and documentation, while others (e.g., InvariTech) offer additional compliance support or risk assessment assistance. Always check what is included.
- Turnaround time: REP27 issues a signed mandate within 24 hours. Other providers may vary—ask for specifics if timing is critical.
- Price transparency: Published, verifiable prices are a sign of reliability. REP27 and EUDR Vault publish clear pricing; InvariTech is on request.
- Documentation and record keeping: Ensure the provider will hold your documentation for the required five years and forward all authority correspondence promptly.
- Limits and extra fees: Some providers limit the number of suppliers, statements, or shipments included in the base price (e.g., EUDR Vault: 10 statements/month). Always clarify before signing.
Included / Not Included / Extra Fees Table
| Provider | Included | Not included | Extra fees |
|---|---|---|---|
| REP27 | Mandate, statement filing, reference numbers, correspondence, 5-year document holding | Due diligence, legal advice, DPO services, liability | None stated |
| EUDR Vault | Supplier/statement limits, evidence storage, audit trail, support | Mandate, legal advice, liability | On request |
| InvariTech | Statement submission, compliance support, risk assessment assistance | Mandate, legal liability (unless stated) | On request |
Always request a service summary in writing and clarify renewal, cancellation, and support processes.
What the Price Really Includes (and Excludes)
The published price for an EUDR authorised representative typically covers only the procedural aspects of compliance:
- Filing due diligence statements in the EU Information System using your supplied data
- Receiving and forwarding correspondence from competent authorities
- Holding documentation for the required five years
- Returning reference numbers for your supply chain
What is not included for most providers:
- Collecting geolocation data or evidence from your suppliers
- Performing risk assessments or mitigation
- Assuming legal liability for compliance failures
- Answering requests from authorities on the merits (REP27 only forwards)
- Legal advice or DPO services
Providers like EUDR Vault may include evidence storage and audit trails, but have limits (e.g., 10 due diligence statements/month). InvariTech lists compliance support and risk assessment assistance, but pricing and detailed inclusions are on request. Always check for per-statement, per-supplier, or per-request fees, and clarify whether support is included or charged extra.
For REP27, the base price (EUR 290/year) covers the essentials for a single operator, with higher tiers (up to EUR 890/year) for multi-entity or complex cases. EUDR Vault’s £49/month plan includes moderate usage limits. For high-volume exporters or those with complex supply chains, always confirm in writing what is included and at what price.
Hidden Costs and What Providers Usually Do Not Say
While most providers publish a base price, there are often hidden costs or limitations that buyers should be aware of:
- Notice periods for cancellation: REP27 renews annually and requires cancellation before the renewal date. Other providers may have similar or stricter terms—always check the contract.
- Limits on included statements or suppliers: EUDR Vault’s base plan includes up to 10 due diligence statements/month and 5 suppliers. Additional usage may incur extra fees, but these are not always clearly published.
- Extra fees for additional requests: Some providers may charge for extra documentation, urgent filings, or support requests. If not stated, request this information in writing.
- Liability exclusions: No provider assumes legal liability for your compliance. The operator or trader is always responsible for the accuracy and completeness of filings, regardless of mandate.
- Scope exclusions: REP27 does not provide legal advice, DPO services, or compliance assessments. It only forwards requests and does not answer on the merits. Other providers may offer compliance support, but always clarify the limits.
What providers rarely say up front: if you are a downstream operator buying from another downstream operator, you are likely outside the EUDR filing obligations and do not need a representative at all. Avoid unnecessary costs by checking your legal position first.
How Appointment Works: Step-by-Step Guidance
Appointing an EUDR authorised representative is a structured process. Here’s how it works in practice:
- Assess your status: Are you a primary operator or exporter placing Annex I products on the EU market? If not, you may not need a representative (see decision matrix below).
- Map your supply chain: Identify all suppliers, production plots, and relevant commodities. Gather geolocation data and legality evidence for each plot.
- Prepare due diligence documentation: Complete a risk assessment and mitigation plan as required by EUDR. This is your responsibility as the operator.
- Select a provider: Compare published prices, inclusions, and support levels. Request a written summary of services, limits, and extra fees.
- Sign the mandate: The provider issues a written mandate (REP27 uses eIDAS electronic signature, issued within 24 hours). This authorises them to act on your behalf for statement filing.
- Submit your data: Provide all required documentation to your representative, including geolocation, legality, and risk assessment records.
- Statement filing: The representative submits your due diligence statement in the EU Information System and returns the reference number, which you must pass down your supply chain.
- Ongoing compliance: Maintain all records for at least five years. The representative will forward any correspondence from authorities but does not answer on your behalf unless specifically agreed.
Checklist for Buyers
- Confirm your EUDR obligations (primary operator, exporter, or exempt downstream).
- Map your supply chain and gather geolocation data.
- Review provider terms and published prices.
- Request a written mandate and clarify included services.
- Prepare for ongoing record keeping and authority correspondence.
Clarify all terms in writing before appointment to avoid misunderstandings.
Risks and Fines: What Happens If You Get It Wrong
Non-compliance with EUDR obligations can result in significant penalties. Failure to appoint an authorised representative when required is a standalone infringement under Article 6. Penalties are set by Member States and can include:
- Substantial administrative fines (proportionate to environmental damage and product value)
- Confiscation of non-compliant goods
- Exclusion from public procurement
Appointment of a representative does not transfer legal responsibility. The operator or trader remains fully liable for the accuracy and completeness of due diligence statements, geolocation data, and legality evidence. Representatives only file and forward correspondence; they do not guarantee compliance or answer authority requests on the merits.
Member States may also require corrective actions, product recalls, or public disclosure of infringements. The risk of enforcement is highest for primary operators and exporters, especially in high-risk supply chains or for products with incomplete traceability. Downstream operators and those dealing only in excluded products are generally not at risk after the 2025 amendment.
Example: The Dutch supervisory authority fined Locatefamily.com EUR 525,000 for failing to appoint a GDPR representative. EUDR fines can be similarly substantial, especially for repeated or intentional breaches.
Decision Matrix: Do You Need an EUDR Authorised Representative?
| If you are... | You need... | You do not need... |
|---|---|---|
| Primary operator outside EU, placing Annex I products on EU market | Authorised representative to file due diligence statements | None |
| Exporter from the EU (non-EU established) | Authorised representative to file statements | None |
| Downstream operator buying from another downstream operator | None | Authorised representative or statement filing |
| First downstream operator | Keep and pass reference number | Statement filing or representative |
| Micro/small enterprise, deadline not yet reached | Monitor for future compliance | Immediate appointment |
| Marketplace seller (Amazon, Etsy, eBay) | Depends on supply chain position (see above) | If not a primary operator/exporter |
Always read the amended regulation before committing to a service. Many companies that budgeted for thousands of filings now need none at all.
Realistic Scenarios: What Applies and Simplest Route
- US SaaS company selling digital goods: Not in EUDR scope. The regulation applies only to physical commodities in Annex I (cattle, cocoa, coffee, oil palm, rubber, soya, wood, and derived products). No representative or statement needed.
- Chinese Amazon seller exporting wood furniture to the EU: If the seller is the first to place the product on the EU market, they must conduct full due diligence and file a statement via an EU-based authorised representative. REP27 or similar providers can be appointed for procedural filing and correspondence.
- UK online shop buying finished chocolate from an EU wholesaler: As a downstream operator buying from another downstream operator, the shop is outside the EUDR filing obligations after the 2025 amendment. No statement or representative is needed. The shop must keep and pass on the reference number if it is the first downstream operator.
These scenarios show why mapping your supply chain and reading the current regulation are essential before appointing a representative.
When you do not need this
- Downstream operators buying only from other downstream operators (no EUDR statement or representative needed after the 2025 amendment).
- Companies dealing only in products not listed in Annex I.
- Micro and small enterprises before their compliance date (30 June 2027).
- Non-EU companies not placing relevant commodities on the EU market or exporting from the EU.
Frequently asked questions
Do I need an EUDR authorised representative if I am a downstream operator?
If you buy from another downstream operator, you are generally outside the EUDR filing obligations after the 2025 amendment. Only primary operators and exporters need to file due diligence statements and may need a representative.
What does an EUDR authorised representative actually do?
The representative submits due diligence statements in the EU Information System on your behalf, receives correspondence from authorities, and holds your documentation for five years. They do not collect data, assess risk, or assume liability.
Is the operator still liable for compliance if a representative is appointed?
Yes. The operator or trader remains fully liable for compliance with the EUDR, regardless of any mandate given to an authorised representative. The representative’s role is procedural only.
What information must I provide to my EUDR authorised representative?
You must provide all required data for the due diligence statement: geolocation of plots, evidence of legality, risk assessment, and mitigation steps. The representative cannot supply or verify this information for you.
How quickly can I appoint an EUDR authorised representative?
REP27 — Europe Services, SE issues a signed mandate within 24 hours. Other providers’ turnaround times vary and may be on request. Always confirm timing before signing.
Are there extra fees for filing multiple statements or adding suppliers?
Some providers limit the number of statements or suppliers included in the base price (e.g., EUDR Vault: 10 statements/month). Always check for extra fees in the provider’s terms and confirm in writing.
Can the authorised representative answer questions from authorities?
The representative receives and forwards correspondence from authorities. They do not answer on the merits or provide legal advice unless specifically agreed. REP27 does not provide legal advice or compliance assessments.
What happens if I do not appoint an authorised representative when required?
Failure to appoint a representative is a standalone infringement under the EUDR. Penalties can include substantial fines, confiscation of goods, and exclusion from public procurement, depending on Member State law.
Does the EUDR apply to digital products or services?
No. The EUDR applies only to certain commodities and products listed in Annex I, such as cattle, cocoa, coffee, oil palm, rubber, soya, and wood. Digital products and services are not covered.
How long must I keep EUDR compliance records?
Operators and traders must keep all records, including due diligence statements and supporting evidence, for at least five years. The representative may hold these for you, but you remain responsible.
Can a UK-based company be an EUDR authorised representative?
No. The representative must be established in an EU Member State. UK-based providers may offer services but must have an EU entity for the mandate to be valid.
What is a simplified declaration under the EUDR?
A simplified declaration is a one-time submission by micro or small primary operators in low-risk countries. It contains the information set out in Annex III and must be submitted before placing relevant products on the market or exporting them.
Sources
- EUDR Authorised Representative | REP27 — gdprrepresentative.com
- EUDR Vault Pricing — eudrvault.com
- InvariTech EUDR Authorised Representative — invaritech.ai
- EUDR FAQ (EFI) — efi.int
- EUDR FAQ (EU Commission) — eudr.webcloud.ec.europa.eu
- EUDR Assistant: Operators & Traders — eudr-assistant.com
- 24hour-AR: EUDR Deforestation Regulation — 24hour-ar.com