EUDR Authorised Representative Services for Operators Outside the EU: Providers & Prices (2026)
- Article 6 EUDR allows non-EU operators to mandate an EU representative to file due diligence statements.
- The representative files, receives correspondence, and retains documentation, but does not take on legal liability.
- Only primary operators and exporters outside the EU generally need this service after the 2025 amendment.
- Medium/large operators must comply from 30 Dec 2026; micro/small from 30 Jun 2027.
- Prices and included services vary; always check what is covered and excluded.
Providers compared
| Provider | Established in | Published price | What the price includes | Best for |
|---|---|---|---|---|
| REP27 — Europe Services, SE | Czech Republic | On request | Filing due diligence statements in the EU Information System, receiving authority correspondence, holding documentation for 5 years, procedural cooperation. Does not perform due diligence or take liability. | Primary non-EU operators/exporters needing a compliant, EEA-wide solution |
| gleborasource | Denmark | On request | Due diligence work, filing of Due Diligence Statement under operator's identity, provision of record for five years. | Operators wanting due diligence support and filing |
| Pier Compliance OÜsource | Estonia | On request | Eligibility and role assessment, mandate coordination, Information System workflow, DDS preparation, submission within the mandate, simplified declaration support, reference management, document-retention support, authority correspondence support, and regulatory monitoring. | Operators seeking full workflow support and compliance monitoring |
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 Key Dates
The EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115 as amended by 2025/2650, imposes strict obligations on operators and traders placing certain commodities and products on the EU market or exporting them from the EU. Article 6 specifically allows operators or traders established outside the EU to appoint an authorised representative established within the EU to submit due diligence statements on their behalf. This provision is designed to facilitate compliance for non-EU companies that do not have a physical presence in the EU, enabling them to interact with the EU Information System and authorities through a local representative.
However, the law is explicit: appointing a representative does not transfer legal responsibility. The operator or trader remains fully liable for compliance, including the accuracy of geolocation data, legality checks, and risk assessments. The representative acts procedurally—filing statements, receiving correspondence, and holding documentation—but cannot perform the core due diligence or assume any liability for non-compliance.
The EUDR covers seven core commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood) and their derived products, as detailed in Annex I. The regulation applies to medium and large operators and traders from 30 December 2026, and to micro and small enterprises from 30 June 2027. The cut-off date for deforestation is 31 December 2020, which has not changed despite postponements. All operators and traders must keep records for at least five years.
Recent amendments (2025/2650) have shifted the filing duty upstream: most downstream operators no longer need to file due diligence statements or appoint a representative. Only primary operators (the first to place a product on the EU market) and exporters outside the EU generally need to appoint an authorised representative. This means that many companies previously preparing for EUDR filings may no longer have this obligation. Always check your supply chain position before contracting a representative.
How to Choose an EUDR Authorised Representative
Choosing the right EUDR authorised representative is critical for non-EU operators who must comply with the regulation. Start by confirming your obligation: are you the primary operator or exporter, or have you been removed from the filing duty by the 2025 amendment? If you do need a representative, compare providers on the following criteria:
- Scope of service: Does the provider only file statements, or do they also help with due diligence preparation, eligibility assessment, or regulatory monitoring?
- Procedural reliability: How quickly do they forward authority correspondence? Are records held for the full five-year period?
- Transparency on exclusions: Do they clearly state what is not included (e.g., actual due diligence, legal liability, extra filings)?
- Experience with your commodity and market: Some providers may have more experience with certain supply chains or product categories.
- Pricing clarity: Is the price structure transparent? Are there extra fees for filings, urgent requests, or additional support?
For example, REP27 — Europe Services, SE provides filing, correspondence, and record retention, but does not perform due diligence or take on liability. glebora includes due diligence work and filing, while Pier Compliance OÜ offers a broader workflow including eligibility assessment, mandate coordination, and regulatory monitoring. Always request a detailed service description and compare what is included and excluded before making a decision.
Below is a detailed comparison of included and excluded services for each provider:
| Provider | Included | Not Included | Extra Fees |
|---|---|---|---|
| REP27 — Europe Services, SE | Filing, correspondence, 5-year record retention, procedural cooperation | Due diligence work, legal liability | On request |
| glebora | Due diligence work, filing, record provision | On request | On request |
| Pier Compliance OÜ | Eligibility assessment, mandate, workflow, DDS prep, submission, reference management, document retention, authority support, monitoring | On request | On request |
What the Price Really Includes: Detailed Comparison
Understanding what is included in the published price is crucial, as EUDR compliance is complex and the scope of service varies widely between providers. Some representatives offer only the bare minimum required by Article 6—filing due diligence statements, receiving correspondence, and record retention—while others include additional support such as due diligence preparation, eligibility assessment, or regulatory monitoring.
For example, REP27 — Europe Services, SE covers the essentials: filing in the EU Information System, prompt forwarding of authority correspondence, and holding documentation for five years. The service is strictly procedural and does not include collecting geolocation data, performing risk assessments, or assuming legal liability. glebora, by contrast, advertises due diligence work as part of their package, which may be valuable for operators who need support preparing the required data. Pier Compliance OÜ offers a comprehensive workflow, including eligibility and role assessment, mandate coordination, DDS preparation, submission, and ongoing regulatory monitoring.
Always verify if the price covers all filings for the year, or if there are extra charges per statement, urgent requests, or additional correspondence. Some providers may charge for each due diligence statement filed, or for additional support beyond the base service. Request a full breakdown and written confirmation of what is included before signing any contract.
Below is a summary table of included and excluded services, based on available data:
| Provider | Included | Not Included | Extra Fees |
|---|---|---|---|
| REP27 — Europe Services, SE | Filing, correspondence, 5-year record retention, procedural cooperation | Due diligence work, legal liability | On request |
| glebora | Due diligence work, filing, record provision | On request | On request |
| Pier Compliance OÜ | Eligibility assessment, mandate, workflow, DDS prep, submission, reference management, document retention, authority support, monitoring | On request | On request |
Hidden Costs and Common Exclusions
Many companies underestimate the true cost of EUDR compliance by focusing only on the published price of an authorised representative. In practice, there are often additional costs and exclusions that can significantly affect your budget and compliance strategy.
- Due diligence work: Most representatives, including REP27 — Europe Services, SE, do not perform the actual due diligence required by Article 4 (e.g., collecting geolocation data, risk assessment, mitigation). This remains the operator's responsibility and can be a major project, especially for complex supply chains.
- Extra filings: Some providers may charge per due diligence statement filed, especially if you have multiple products or shipments. Always clarify if the base price covers all filings or only a set number.
- Urgent requests and correspondence: There may be surcharges for urgent filings, expedited correspondence with authorities, or additional support beyond standard service levels.
- Legal liability: No provider assumes legal responsibility for EUDR compliance. The operator remains fully liable, regardless of the representative's actions.
- Notice periods and contract terms: Some providers may require advance notice for termination or changes in service, and may charge fees for early termination or amendments.
Before contracting, request a full list of included and excluded services, ask about per-request fees, and clarify all contract terms. This will help avoid surprises and ensure that your compliance budget is realistic.
How Appointment Works: Step by Step
Appointing an EUDR authorised representative is a structured process. Here is a step-by-step guide to ensure compliance:
- Determine your obligation: Use the decision matrix below to confirm whether you are required to appoint a representative. Only primary operators and exporters outside the EU generally need this service after the 2025 amendment.
- Map your supply chain: Identify all suppliers and the origin of commodities. Confirm if your products fall under EUDR Annex I.
- Collect due diligence data: Gather geolocation data for every plot, evidence of legality in the country of production, risk assessments, and mitigation measures. This is the most time-consuming part and cannot be delegated to the representative.
- Choose a provider: Evaluate authorised representatives based on included services, exclusions, price, and experience with your commodity.
- Sign a written mandate: The mandate must be in writing, authorising the representative to file due diligence statements on your behalf. Ensure the mandate is clear about the scope and limitations.
- Provide documentation: Submit all required due diligence data to your representative for filing.
- Filing and reference number: The representative files the due diligence statement in the EU Information System and returns the reference number, which must be passed down the supply chain.
- Record retention: Both you and the representative must retain all records for at least five years.
- Ongoing compliance: Respond promptly to any authority correspondence forwarded by your representative, and update due diligence data as needed for new consignments.
Checklist for buyers:
- Check if your products are in EUDR Annex I.
- Determine your position in the supply chain (primary operator, downstream, exporter).
- Review the compliance deadline for your company size.
- Collect all required due diligence data (geolocation, legality, risk assessment).
- Evaluate and contact authorised representative providers.
- Clarify included services, exclusions, and all fees.
- Sign a written mandate if needed.
- Submit due diligence data for filing and retain the reference number.
Risks, Fines, and What Providers Usually Do Not Say
Non-compliance with the EUDR can have severe financial and reputational consequences. Fines can reach up to EUR 15 million or 3% of global turnover, and authorities may confiscate non-compliant products or exclude companies from public procurement. The regulation is enforced by national competent authorities in each EU Member State, and checks are risk-based, focusing on high-risk countries and supply chains.
Providers often do not highlight certain critical points:
- Liability remains with the operator: Appointing a representative does not shield you from fines or enforcement actions. You are responsible for the accuracy and completeness of all due diligence data.
- Due diligence is not included: Most representatives do not collect geolocation data, assess risk, or mitigate non-compliance. This work must be done before the representative can file a statement.
- Extra fees and exclusions: Additional filings, urgent requests, or extended support may incur extra charges. Always clarify the fee structure.
- Notice periods and contract terms: Early termination or changes may involve fees or waiting periods.
- Downstream operators often do not need a representative: After the 2025 amendment, most downstream companies are outside the filing obligations and should not pay for unnecessary services.
To avoid unexpected costs or compliance failures, demand full transparency from providers and read the amended regulation carefully before contracting.
Decision Matrix: Who Needs an EUDR Authorised Representative?
Use this matrix to determine your obligation under the EUDR:
| If you are... | You need... | You do not need... |
|---|---|---|
| Primary operator/exporter outside EU, placing covered commodities on EU market | EUDR authorised representative | - |
| First downstream operator (buying from a primary operator) | Collect and pass reference number | No representative |
| Downstream buying from downstream | - | No representative or statement |
| Micro/small operator (before 30 June 2027) | Prepare data, wait for deadline | No immediate representative |
| Marketplace seller (Amazon, Etsy, eBay) | Depends on supply chain position | Usually no representative if not primary operator |
Examples:
- A US coffee exporter (primary operator) must appoint a representative to file EUDR statements for EU shipments.
- A UK online shop buying from an EU distributor does not need a representative, as it is not the first to place goods on the EU market.
- A Chinese Amazon seller acting as a primary operator must appoint a representative; if only reselling, no representative is needed.
Three Realistic Scenarios Explained
- US SaaS company exporting coffee to the EU: As the primary operator, the company must collect geolocation data for every plot, verify legality, perform risk assessment, and mitigate any risks. Once all data is ready, it appoints an EU-based authorised representative (e.g., REP27 — Europe Services, SE) to file the due diligence statement in the EU Information System. The reference number is then passed down the supply chain. The company remains liable for all data accuracy and compliance.
- Chinese Amazon seller: If the seller is the first to place covered commodities (e.g., wood products) on the EU market, it must appoint an authorised representative to file due diligence statements. If the seller is only reselling goods already placed on the EU market by another operator, no representative is required after the 2025 amendment. The seller should keep and pass on the reference number received from their supplier.
- UK online shop buying from an EU distributor: The shop is not the primary operator and does not need to file due diligence statements or appoint a representative. Its obligation is to keep and pass on the reference number provided by the distributor, ensuring traceability but not direct compliance filing.
When you do not need this
- Downstream operators buying from other downstream operators (no filing duty after the 2025 amendment)
- Companies not placing EUDR-covered commodities or products on the EU market
- Micro and small enterprises before 30 June 2027 (unless exporting or acting as primary operator)
- B2B companies not acting as primary operator or exporter
Frequently asked questions
What does an EUDR authorised representative do for non-EU operators?
They file due diligence statements in the EU Information System, receive and forward authority correspondence, and retain documentation for five years. They do not perform due diligence or assume legal liability for compliance.
Who needs to appoint an EUDR authorised representative?
Only primary operators and exporters outside the EU who must file due diligence statements under the EUDR need to appoint a representative. Most downstream operators no longer need this after the 2025 amendment.
Does appointing a representative transfer legal responsibility?
No. The operator remains fully liable for compliance, including the accuracy of all data and due diligence. The representative only handles procedural filing and correspondence.
What is the deadline for compliance?
Medium and large operators must comply from 30 December 2026. Micro and small enterprises must comply from 30 June 2027.
What commodities are covered by the EUDR?
Cattle, cocoa, coffee, oil palm, rubber, soya, wood, and their derived products as listed in Annex I of the regulation.
What records must be kept and for how long?
All due diligence and supply chain records must be kept for at least five years under the EUDR.
Can the representative perform due diligence on my behalf?
No. Due diligence (e.g., collecting geolocation, risk assessment) must be performed by the operator. The representative can only file what you provide.
Are there hidden costs with EUDR representatives?
Some providers may charge extra for filings, urgent requests, or extended support. Always clarify all fees and exclusions before contracting.
What happens if I do not appoint a representative when required?
Failure to comply can result in fines up to EUR 15 million or 3% of turnover, and possible exclusion from the EU market.
Do marketplace sellers (Amazon, Etsy, eBay) need an EUDR representative?
Only if they are the primary operator placing covered commodities on the EU market. Most resellers or downstream operators do not need a representative after the 2025 amendment.
How do I know if I am a primary operator or downstream operator?
A primary operator is the first to place a covered commodity or product on the EU market. Downstream operators buy from other operators. The 2025 amendment removed most downstream operators from the filing obligation.
Can I change my authorised representative later?
Yes, but check contract terms for notice periods or fees. Ensure a smooth transition to avoid gaps in compliance or record retention.
Sources
- EUDR Authorised Representative | REP27 — gdprrepresentative.com
- EUDR Deadlines and Scope | REP27 — gdprrepresentative.com
- EUDR Due Diligence Statement | REP27 — gdprrepresentative.com
- glebora – Authorised Representative — glebora.com
- Pier Compliance OÜ – EUDR Compliance — piercompliance.com
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