How to Compare EUDR Authorized Representative Services Effectively

• EUDR Article 6 lets non-EU operators/traders mandate an EU representative for due diligence filings.
• REP27 — Europe Services, SE covers all EEA states for EUR 290–890/year, with 24-hour designation and full EUDR scope.
• Most market providers focus on GPSR, not EUDR; always check if EUDR filings are included.
• The 2025 amendment shifted most EUDR filing duties upstream—many downstream firms now have no filing duty.
• Always review what’s included, request a breakdown of extra fees, and confirm your legal obligation before buying.

Updated 21 October 2026 · 8 sources checked

Providers compared

Prices as published on each provider's website on 21 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires: EUDR Article 6 and the 2025 Amendment

The European Union Deforestation Regulation (EUDR), Regulation (EU) 2023/1115 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 of the EUDR allows non-EU operators and traders to mandate an authorized representative (AR) established in the EU to submit due diligence statements and handle correspondence with authorities. However, this mandate does not transfer liability: the operator or trader remains fully responsible for compliance, including the accuracy and completeness of the underlying due diligence.

The 2025 amendment (Regulation (EU) 2025/2650) significantly changed the filing landscape. It postponed the main application dates to 30 December 2026 for medium and large operators and traders, and 30 June 2027 for micro and small enterprises. Most importantly, it moved the filing duty upstream: only primary operators and certain exporters must file due diligence statements, while most downstream operators and traders are now exempt from filing and only need to keep and pass on reference numbers. This means that many companies that previously expected to file thousands of statements may now have no filing duty at all.

Key requirements under the law:

• Article 6: Allows appointment of an EU-based AR for filings and correspondence.
• Article 8–11: Set out the due diligence statement content, including geolocation, legality, risk assessment, and mitigation.
• Annex I: Lists the seven covered commodities and derived products (e.g., cocoa, coffee, soy, wood, beef, palm oil, rubber).
• Retention: All operators must keep records for five years.
• Penalties: Set by Member States, proportionate to environmental damage and product value, and may include confiscation or exclusion from procurement.

Before seeking an EUDR AR, companies must carefully determine their position in the supply chain and confirm if they are still required to file under the amended regulation.

How to Choose a Provider: Scope, Coverage, and Inclusions

Choosing the right authorized representative is critical for EUDR compliance. The market is dominated by providers offering GPSR (General Product Safety Regulation) responsible person services, but very few explicitly cover EUDR Article 6 filings. The distinction is crucial: GPSR ARs are required for product safety compliance, not for EUDR due diligence filings. Always confirm the provider’s scope before purchasing.

Key criteria to evaluate:

• Regulation coverage: Does the provider explicitly offer EUDR Article 6 services, or only GPSR AR?
• Geographic coverage: Does the service cover all EEA states, or just one country?
• Designation process: How quickly is the designation letter issued? Is it signed electronically and verifiable?
• Certificate and verification: Does the provider issue a certificate with QR code and public verification page?
• Included services: Are filings, authority correspondence, and document retention included in the base price?
• Response times: How quickly does the provider forward authority or data subject requests?

For example, REP27 — Europe Services, SE covers all EEA states, issues a designation within 24 hours (with eIDAS electronic signature and QR code certificate), includes authority correspondence and document retention for five years, and forwards requests within two business days. Most other providers in the comparison table focus solely on GPSR AR and do not offer EUDR filings at all.

Included / Not Included / Extra Fees Table (October 2026)

Always request written confirmation of what is included and excluded, and ask for a sample certificate and mandate before committing.

What the Price Really Includes (and Excludes)

Published prices for authorized representative services vary widely and can be misleading if you do not check the scope. Most providers in the current market publish prices for GPSR responsible person services, not for EUDR Article 6 filings. For EUDR, always confirm:

• Geographic scope: Is the price for all EEA states or only one country?
• Product scope: Does the price cover all your product types, or is there a separate fee per commodity or filing?
• Document retention: Are five years of record-keeping included?
• Authority correspondence: Is this included, and what are the response times?
• Certificate and verification: Is a verifiable certificate with QR code included?

REP27 — Europe Services, SE offers EUDR Article 6 filings for EUR 290–890 per year, covering all EEA states, with designation in 24 hours, a verifiable certificate, and five-year document retention. The price does not include liability transfer or the due diligence work itself—these remain the client’s responsibility. For GPSR AR, prices range from EUR 99/month (AuraDPP) to EUR 1190/year (Cert‑Rep), but these do not cover EUDR filings.

Always ask for a full price breakdown, including possible extra fees for additional products, filings, or requests. If your provider cannot confirm EUDR coverage in writing, you may not be compliant. A sample price breakdown request:

• Base fee (per year)
• Fee per additional product/commodity
• Fee per additional filing
• Authority correspondence included?
• Document retention included?

Never assume that a GPSR AR service will meet EUDR requirements unless explicitly stated.

Hidden Costs and Exclusions: What Providers Usually Do Not Say

Many authorized representative providers do not publish all relevant costs or exclusions. This can lead to unexpected expenses or compliance gaps. Common hidden costs and exclusions include:

• Notice periods: Some providers require long notice periods for termination or renewal, which may lock you into annual contracts.
• Additional filings: Fees may apply for each additional due diligence statement or product type, especially for high-volume sellers.
• Authority requests: Some providers charge extra for forwarding or responding to authority or data subject requests.
• Liability limits: No provider, including REP27, accepts legal liability for your compliance; the operator or trader remains responsible for all due diligence and data accuracy.
• Exclusions: Many providers do not cover EUDR filings at all, even if they offer AR services for GPSR or other regulations.
• Document retention: Not all providers include the five-year record-keeping required by EUDR.

For example, REP27 — Europe Services, SE clearly states that it does not transfer liability or perform the due diligence work itself. It provides the filing, correspondence, and document retention, but the client must collect geolocation data, assess risk, and mitigate it. Most GPSR AR providers do not mention EUDR at all, and their published prices do not include EUDR filings.

Before signing, always:

• Request a full list of exclusions and extra fees in writing.
• Ask for the provider’s standard notice period and renewal terms.
• Clarify if there are per-request or per-filing charges.
• Confirm that the service covers EUDR Article 6 filings if that is your need.

Transparency on these points is essential to avoid compliance risks and unexpected costs.

How Appointment Works: Step by Step

The process to appoint an EUDR authorized representative is straightforward but must be carefully followed to ensure compliance. Here is a detailed step-by-step guide:

1. Determine your filing duty: Review your supply chain position after the 2025 amendment. Only primary operators, certain exporters, and some micro/small operators in low-risk countries must file due diligence statements. Most downstream operators and traders are now exempt from filing.
2. Identify a suitable provider: Choose a provider that explicitly covers EUDR Article 6 filings (not just GPSR AR), with coverage for all EEA states if required.
3. Request a service proposal: Ask for a written offer detailing all included services, exclusions, and extra fees. Request a sample designation letter and certificate.
4. Sign the mandate: Enter into a written agreement with the provider. For REP27, the designation is issued within 24 hours, signed electronically (eIDAS), and includes a verifiable QR code certificate.
5. Prepare due diligence documentation: Gather geolocation data for all plots, evidence of legality in the country of production, a written risk assessment, and evidence of risk mitigation. This is your responsibility as the operator or trader.
6. Submit documentation: Provide the required data to your authorized representative for filing. The representative submits the due diligence statement in the EU Information System and returns the reference number.
7. Record and pass on reference numbers: The reference number is required for your commercial documentation and must be passed down the supply chain as needed.
8. Ongoing correspondence: The representative receives and forwards any correspondence from competent authorities, logs requests, and retains all documentation for the required five-year period.

Checklist for buyers:

1. Confirm your legal duty to file.
2. Request a full service breakdown.
3. Sign a written mandate.
4. Obtain a verifiable certificate.
5. Provide all due diligence data.
6. Retain all records for five years.

Risks, Fines, and Compliance Consequences

Appointing an EUDR authorized representative does not remove your compliance obligations. Under Article 6, the AR files statements and handles correspondence, but the operator or trader remains fully liable for all due diligence, data accuracy, and compliance with the regulation. The risks of non-compliance are significant:

• Fines: Penalties are set by each Member State and are proportionate to the environmental damage and value of the products involved. They may include substantial financial penalties, confiscation of goods, and exclusion from public procurement.
• Enforcement actions: Authorities may require the production of supporting documentation, conduct checks, and investigate supply chains. Failure to provide accurate data or to appoint a representative when required can trigger enforcement.
• Reputational risk: Public enforcement actions or exclusion from procurement can damage your brand and market access.
• No liability transfer: Even with an AR, you remain responsible for all due diligence work and the truthfulness of every statement filed. If incorrect or incomplete data is submitted, you—not your AR—face the consequences.

Practical implications:

• If you are a non-EU operator placing covered commodities on the EU market, failing to appoint an AR (when required) or filing incomplete statements can result in immediate enforcement.
• Downstream operators who no longer have a filing duty after the 2025 amendment should not appoint an AR unnecessarily, as this adds cost without reducing risk.
• Always keep all due diligence records, reference numbers, and correspondence for at least five years, as required by the regulation.

Summary: The AR is a procedural delegate, not a shield. Compliance remains your responsibility, and penalties for non-compliance can be severe.

Decision Matrix: Do You Need an EUDR Authorized Representative?

Use this decision matrix to determine if you need to appoint an EUDR authorized representative based on your company’s position, size, and activities:

Summary:

• If you are not placing EUDR-covered commodities on the EU market, you do not need an EUDR AR.
• If you are a downstream operator buying only from other downstream operators, you are outside the EUDR filing obligations after the 2025 amendment.
• Always verify your filing duty before purchasing any AR service.

Checklist: Steps to Take Before Appointing an EUDR AR

1. Check product scope: Are your products or commodities listed in EUDR Annex I (as amended)?
2. Determine your supply chain position: Are you a primary operator, exporter, or downstream operator?
3. Review the 2025/2650 amendment: Confirm if you still have a filing duty or if you are now exempt.
4. Gather due diligence data: Collect geolocation of plots, evidence of legality, risk assessment, and mitigation measures.
5. Request detailed quotes: Ask potential providers for a full breakdown of included services, exclusions, and extra fees.
6. Confirm EUDR Article 6 coverage: Ensure the provider covers EUDR filings and all EEA states if required.
7. Sign the mandate: Enter into a written agreement and obtain a verifiable certificate.
8. File the due diligence statement: Submit your data to the AR for filing in the EU Information System.
9. Retain all records: Keep all documentation, reference numbers, and correspondence for at least five years.
10. Monitor regulatory changes: The EUDR is subject to further amendments and delegated acts; stay informed to maintain compliance.

This checklist ensures you only appoint an AR when truly required and that your compliance process is robust and documented.

Realistic Scenarios: Who Needs What and Why

• Scenario 1: US SaaS Company Selling to EU Businesses
  A US-based SaaS provider sells software to EU clients. Since no physical commodities are placed on the EU market, EUDR does not apply. No EUDR AR is required. However, if personal data is processed, a GDPR Article 27 representative may be needed instead.
• Scenario 2: Chinese Amazon Seller Exporting Wood Furniture to the EU
  A Chinese manufacturer sells wood furniture (a covered commodity) on Amazon EU. The seller is a primary operator placing products on the EU market, so from December 2026 (if medium/large) or June 2027 (if micro/small), an EUDR AR is required for due diligence filings. The seller also needs a GPSR AR for Amazon listing compliance, but most AR providers only cover GPSR, not EUDR. REP27 is one of the few offering EUDR AR service.
• Scenario 3: UK Online Shop Selling Chocolate to the EU
  A UK-based online retailer exports chocolate (covered under EUDR) to EU customers. If acting as a primary operator, the company must file due diligence statements and appoint an EUDR AR from December 2026 (medium/large) or June 2027 (micro/small). If only acting as a downstream operator, it may only need to collect and pass on reference numbers, not file or appoint an AR. The company should confirm its position before buying any service.

These scenarios illustrate the importance of verifying your supply chain role and product scope before engaging an EUDR AR. Appointing an AR unnecessarily adds cost without reducing compliance risk.