Service agreement · Article 6 · Regulation (EU) 2023/1115

EUDR Authorised Representative — Terms and Conditions

Terms under which Europe Services, SE acts as authorised representative of operators and traders under Article 6 of the EU Deforestation Regulation, submitting due diligence statements to the EU Information System on their behalf.

Version 1.0In force from 27 October 2026Business customers onlyLanguage: English

In short: we register as your authorised representative, check your shipment data and submit your due diligence statements in the EU Information System, without a fee per shipment; you remain the operator and responsible for the compliance of your products (Article 6 and Article 3 of the Regulation).

Parties

(1) Europe Services, SE, a European company registered in the Czech Republic, company ID (IČO) 03571785, entered in the commercial register kept by the Municipal Court in Prague, file H 1486, with its registered office at Na Čečeličce 425/4, Smíchov, 150 00 Praha 5, Czech Republic (the “Provider” or “Authorised Representative”); and

(2) the company identified in the Designation as the operator or trader (the “Client”).

1. Definitions and interpretation

1.1

In this Agreement: “Regulation” or “EUDR” means Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation, as amended (including by Regulation (EU) 2024/3234 and Regulation (EU) 2025/2650), together with its implementing and delegated acts and the guidance of the European Commission;

1.2

“Provider” or “Authorised Representative” means Europe Services, SE; “Client” means the company named in the Designation; “Designation” means the designation letter signed electronically by the Client and accepted by the Provider, identified by a verification code beginning with E06-;

1.3

“Relevant Commodities” means cattle, cocoa, coffee, oil palm, rubber, soya and wood, and “Relevant Products” means the products listed in Annex I to the Regulation that contain, have been fed with or have been made using Relevant Commodities; “Product” means each Relevant Product of the Client covered by the Plan, a product sold in several sizes, colours or finishes counting as one Product where its composition and supply chain are the same;

1.4

“Operator”, “Trader”, “placing on the market”, “export”, “due diligence statement” (“DDS”), “geolocation”, “plot of land”, “negligible risk” and “competent authority” have the meaning given in the Regulation; “Information System” means the information system referred to in Article 33 of the Regulation (currently accessible through TRACES);

1.5

“Shipment Data” means the information listed in Schedule 2 for a given placing on the market or export; “Plan” means the plan purchased by the Client (Schedule 3); “Client Area” means the secure area at gdprrepresentative.com/account.php; “Working Day” means a day other than a Saturday, Sunday or public holiday in the Czech Republic;

1.6

Headings are for convenience only. “Including” means “including without limitation”. A reference to the Regulation or to any article of it includes that provision as amended or replaced from time to time.

2. Appointment and scope

2.1

The Client appoints the Provider as its authorised representative under Article 6 of the Regulation to submit due diligence statements to the Information System on the Client’s behalf, and the Provider accepts the appointment from the date of acceptance shown on the Designation, under the terms of this Agreement.

2.2

The appointment covers the Products declared in the designation form and those added under clause 11, for placing on the market of the European Union and, where the Client has selected it, of Northern Ireland, where the Regulation applies under the Windsor Framework, and for export from those territories.

2.3

In accordance with Article 6 of the Regulation, the appointment does not transfer to the Provider the obligations of the Client as Operator or Trader. The Client remains fully responsible for the compliance of the Relevant Products with Article 3 of the Regulation (deforestation-free, produced legally and covered by a DDS), for the due diligence system it maintains and for the accuracy of the information it provides.

2.4

The Provider does not become the importer, the declarant, the indirect customs representative, the owner or the Operator of any goods, and does not place goods on the market in its own name.

2.5

The Provider acts on the Client’s instructions and on the basis of the Shipment Data and documents the Client supplies. It may rely on them without independent verification, save for the checks described in clause 4.

3. Review and acceptance of the Designation

3.1

After payment, the Client completes the designation form, which records its company details, its Products, HS/CN codes, Relevant Commodities, countries of production, suppliers, role, size, markets, estimated volumes and the availability of geolocation data, and signs the Designation electronically.

3.2

The Provider reviews the file within one Working Day. It may ask for clarifications or documents. It may decline the Designation, in particular where the products are not Relevant Products, where the Client or its supply chain is subject to sanctions, or where the information is manifestly false or incomplete; in that case the amount paid is refunded in full and the reason is given in writing.

3.3

On acceptance, the Provider countersigns the Designation, issues the certificate and publishes the public verification page for the verification code. The Designation is effective from the date of acceptance shown on it.

3.4

Where the Client has declared more Products than its Plan covers, the Provider informs the Client before acceptance and the Client moves to the appropriate Plan under clause 11.

4. Our services

4.1

Registration. The Provider registers or links its authorised-representative account in the Information System for the Client, so that DDS can be submitted on the Client’s behalf.

4.2

Product files and risk assessment support. For each Product, the Provider opens a file with the supply-chain information supplied by the Client and prepares, once a year and whenever the supply chain changes, a documented risk-assessment record structured on the criteria of Article 10 of the Regulation and the country benchmarking under Article 29, together with any mitigation measures the Client decides to apply. The Client reviews and approves the record; the conclusions and the decision to place the Product on the market remain the Client’s.

4.3

Supplier requests. The Provider supplies ready-to-send requests (in English and, on request, in the supplier’s language) for the geolocation, species, country of production and evidence of legality required from suppliers, and checks the replies the Client forwards.

4.4

Checks before submission. Before each DDS, the Provider checks that the Shipment Data are complete and consistent: HS/CN code against Annex I, quantity and unit, country of production, geolocation in a format accepted by the Information System (points, or polygons for plots of land of more than four hectares used for commodities other than cattle), production dates or range, and supplier and customer details. Where available, the Provider may compare the geolocation with public forest-cover data as an indicative step; this comparison is not a certification and does not replace the Client’s due diligence.

4.5

Submission of DDS. When the Shipment Data are complete, the Provider submits the DDS in the Information System on the Client’s behalf within the times in Schedule 1 and sends the Client the reference number and verification number to give to customs or to its courier, and records them in the Client Area.

4.6

Amendments and withdrawals. On the Client’s instructions, the Provider amends or withdraws a DDS where the Information System allows it, or submits a new DDS.

4.7

Use of existing statements. Where the Client is a downstream operator or trader, or relies on statements already submitted upstream, the Provider records the reference numbers received and uses them as the Regulation allows.

4.8

Authorities. The Provider forwards to the Client, within two Working Days, any request it receives from a competent authority concerning the Client, and assists the Client in assembling the documents to answer it.

4.9

Records. The Provider keeps the DDS submitted, the Shipment Data and the supporting documents received for five years from the date of each DDS, as Article 12 of the Regulation requires the Operator to do, and gives the Client access to them in the Client Area and on request.

4.10

Client Area and updates. The Client Area shows the Designation, the certificate, the DDS submitted, invoices and receipts. The Provider informs the Client of material changes to the Regulation and to the Information System that affect the service.

4.11

The number of DDS is unlimited for the Products of the Plan: there is no fee per shipment or per DDS.

5. What is not included

5.1

Unless agreed in writing, the service does not include: (a) legal advice beyond the matters covered by this Agreement; (b) customs clearance, brokerage, EORI registration or acting as declarant, importer of record or customs representative; (c) on-site audits, field verification of plots, laboratory tests, satellite monitoring services or certification; (d) the choice of suppliers or of mitigation measures; (e) the Client’s other obligations under EU or national law, including tariff classification, product safety, labelling and the national implementation of penalties; (f) translations of supplier documents other than into English.

5.2

The Provider does not guarantee that a DDS will not be checked, challenged or rejected by a competent authority, nor that goods will be released by customs.

6. Your obligations

6.1

The Client provides the Shipment Data listed in Schedule 2 for each placing on the market or export at least two Working Days before the goods are presented to customs or made available on the market, using the template or upload in the Client Area or by email to info@gdprrepresentative.com.

6.2

The Client ensures that the Shipment Data and the documents are complete, accurate, verifiable and not misleading, that it has carried out due diligence under Articles 8 to 11 of the Regulation and concluded that the risk is no more than negligible, and that it holds adequately conclusive and verifiable information supporting that conclusion.

6.3

The Client does not ask the Provider to submit a DDS for products it knows or has reason to believe are not compliant, and informs the Provider at once of any new information indicating a risk, of any change of supplier, product, country of production or plot, and of any request, check or measure of a competent authority.

6.4

The Client keeps its own records under the Regulation, cooperates with competent authorities and with the Provider, implements corrective measures ordered by an authority, and pays the fees when due.

6.5

The Client is responsible for the correct HS/CN classification of its goods and for the declarations made to customs.

7. Northern Ireland and other territories

7.1

Where the Client has selected Northern Ireland, the Provider submits DDS for goods placed on the market there in the same way as for the Union, as the Regulation applies in Northern Ireland under the Windsor Framework. The Client informs the Provider of any change in the rules applicable to Northern Ireland that it becomes aware of.

7.2

The Regulation does not apply to Great Britain. Any separate regime introduced in Great Britain is not covered unless agreed in writing.

8. Use of our name

8.1

The Client may state that Europe Services, SE acts as its EUDR authorised representative and may show the verification code and the public verification page. It may not state or imply that the Provider certifies, audits or guarantees the deforestation-free status or legality of its products.

9. Authorities, checks and corrective action

9.1

Competent authorities may check the Client and its Products under Articles 16 to 18 of the Regulation. The Client answers them, with the Provider’s assistance under clause 4.8, within the deadline set by the authority.

9.2

Where an authority finds a non-compliance, takes interim measures or imposes penalties, the consequences are borne by the Client as Operator or Trader. The Provider informs the authority, where asked, of the instructions and data it received from the Client.

10. Fees, invoicing and payment

10.1

The fees are those of the Plan shown on gdprrepresentative.com at the date of purchase (Schedule 3), or those stated in a written quote. Plans differ only by the number of Products covered. They are invoiced and collected by the Provider through its payment processors (Mollie or PayPal).

10.2

Fees are payable yearly in advance or, where the Client has chosen monthly billing, monthly in advance for a binding minimum period of twelve months; the twelve monthly instalments are due even if the Client stops the renewal earlier. Monthly instalments include a surcharge compared with the yearly fee, shown at checkout.

10.3

Prices exclude VAT. No Czech VAT is charged to customers established outside the European Union. For customers established in the European Union with a valid VAT number, the reverse-charge mechanism applies; Czech VAT at 21% is charged where the law requires it.

10.4

Fees are stated in euros (EUR) and the contractual price is always the EUR amount. Where the Client chooses to pay in US dollars (USD), pounds sterling (GBP), Canadian dollars (CAD), Australian dollars (AUD), New Zealand dollars (NZD), Swiss francs (CHF), Czech korunas (CZK), Japanese yen (JPY) or Norwegian kroner (NOK), the amount charged is the equivalent of the EUR fee converted at the most recent euro foreign exchange reference rate published by the European Central Bank at the time of payment; this option is available only where no VAT is charged. The invoice states both amounts and the rate applied. Renewals and monthly instalments are charged in the same currency as the first payment, converted from the EUR fee at the most recent ECB reference rate published before each charge; refunds are made in the currency of the original payment. Bank or card conversion charges are borne by the Client.

10.5

An invoice and a payment receipt are issued for every payment and are available in the Client Area and by email.

10.6

The Provider may change its list prices at any time; a change applies to existing Clients only from their next renewal and only after at least thirty days’ notice, during which the Client may stop the renewal without charge.

10.7

If a payment fails, the Designation remains active during a grace period of eight days, after which the Provider stops submitting DDS and the Designation is shown as suspended on the public verification page until payment is made.

10.8

If the Provider declines the Designation before accepting it, it refunds the amount paid. Otherwise, no refund is due for a period already paid, except as required by law.

10.9

A free trial, where offered at checkout, lasts for the number of days shown; no DDS is submitted during the trial until the first payment is made, unless the Provider agrees otherwise in writing.

10.10

Annual plan in instalments. Where offered (gdprrepresentative.com/eudr-instalments.php), the Client may pay the yearly fee of its Plan in the number of monthly instalments it chooses within the range shown, with no interest and no surcharge. The first instalment is paid at checkout and authorises the following instalments to be charged automatically to the same payment method on the same day of each following month, with a reminder two days before each charge. The Plan is an annual commitment: all instalments of the year remain due even if the renewal is stopped. If an instalment is not received, the Designation remains active for eight days, the charge is retried and the Client may pay it at any time with the link sent; after eight days the Designation is suspended and it is reactivated as soon as the payment is received. At renewal, the renewal fee is again split into the same number of instalments, with notice at least thirty days before the expiry date; the Client may stop the renewal before the first instalment of the new year. Each paid instalment is invoiced separately. With a free trial, the first instalment is due at the end of the trial and the schedule starts from the day it is paid.

11. Adding and changing products

11.1

The Client may add Products at any time from the Client Area (“Add products”), giving for each Product its trade name, HS/CN code, Relevant Commodity, country of production and supplier, or by writing to the Provider. Products within the limit of the Plan are added without charge.

11.2

If the number of Products exceeds the limit of the Plan, the Client moves to the smallest Plan that covers them; beyond the largest Plan, each additional Product is charged at the additional-product fee in Schedule 3. With yearly billing or the annual plan in instalments, the Client pays at once only the difference in the yearly fee for the days remaining in the current term, and the next renewal (or the next year’s instalments) is charged on the new Plan and number of additional Products. With monthly billing nothing is charged at once and the new monthly amount applies from the next instalment. The Products are added, and the change of Plan takes effect, when the payment is confirmed; an invoice is issued and the Client receives a confirmation by email.

11.3

Products added are listed in an annex to the Designation with the date of addition; the rest of the Designation is unchanged. The Client confirms that the added products are Relevant Products and that the information given is accurate.

11.4

The Client may move to a lower Plan with effect from the next renewal.

12. Term, renewal and cancellation

12.1

This Agreement starts on the date of acceptance of the Designation and runs for twelve months. It renews automatically for successive periods of twelve months unless the Client stops the renewal in the Client Area or by email before the renewal date, subject to clause 10.2 for monthly billing.

12.2

The Provider may decide not to renew by giving thirty days’ notice before the renewal date.

13. Suspension and termination for cause

13.1

The Provider may suspend the submission of DDS, or terminate this Agreement with immediate effect by written notice, if the Client: (a) provides information that is false or misleading; (b) asks the Provider to submit a DDS for products it knows or should know are not compliant; (c) fails to pay after the grace period; (d) becomes subject to sanctions; (e) fails to cooperate with a competent authority; or (f) commits another material breach not remedied within fourteen days of notice.

13.2

Either party may terminate this Agreement if the other becomes insolvent or ceases its business.

14. End of the service

14.1

When this Agreement ends, the Provider stops submitting DDS, updates the public verification page, revokes or ends its authorised-representative link in the Information System where possible and, on request within thirty days, sends the Client a copy of the DDS references and Shipment Data in its files.

14.2

DDS already submitted remain valid as submitted. The Provider continues to keep the records under clause 4.9 for the remainder of the five-year period.

15. Indemnity

15.1

The Client indemnifies the Provider against any penalty, claim, loss, cost or expense (including reasonable legal fees) arising from inaccurate, incomplete or misleading information supplied by the Client or its suppliers, from the non-compliance of the Client’s products, or from the Client’s breach of this Agreement or of the Regulation.

16. Limitation of liability

16.1

Nothing in this Agreement limits or excludes liability for death or personal injury caused by negligence, for fraud, for wilful misconduct or gross negligence, or for any other liability that cannot be limited or excluded by law.

16.2

Subject to clause 16.1, the total liability of the Provider, in contract, tort (including negligence) or otherwise, arising under or in connection with this Agreement in any period of twelve months, is limited to the fees paid by the Client under this Agreement in the twelve months before the event giving rise to the claim.

16.3

Subject to clause 16.1, the Provider is not liable for loss of profit, revenue, sales, business, goodwill or data, for goods held at customs, for delisting by a marketplace, for penalties imposed on the Client, or for any indirect or consequential loss, nor for delays caused by the unavailability of the Information System or by late or incomplete Shipment Data.

17. Confidentiality

17.1

The Provider keeps the Client’s supply-chain information, including suppliers, prices, geolocation data and volumes, confidential, and uses it only to perform this Agreement, to comply with the law and to answer competent authorities. Access is limited to the staff and advisers who need it.

18. Personal data

18.1

Each party complies with the General Data Protection Regulation. The Provider processes the personal data of the Client’s contacts and of supplier contacts contained in the Shipment Data as described in its privacy notice at gdprrepresentative.com/privacy/. Where the Provider processes personal data on the Client’s behalf, the Data Processing Agreement published on the website applies.

19. Changes in the law and to this Agreement

19.1

The Regulation, its application dates, the Information System and the Commission guidance may change. The Provider may adapt the service and this Agreement to reflect such changes; it informs the Client of material changes at least thirty days in advance, or as soon as possible where the change results from the law. If a change materially reduces the service, the Client may terminate with effect from the date of the change and obtain a pro rata refund of fees paid in advance.

19.2

The deadlines of the Regulation that apply to the Client (currently 30 December 2026 for medium and large operators and 30 June 2027 for micro and small operators, subject to the transitional rules of the Regulation) are the Client’s responsibility; the Provider informs the Client of them as a courtesy.

20. Sanctions and compliance

20.1

The Client confirms that neither it, its owners, directors nor, to its knowledge, its suppliers are subject to EU, UN, UK or US sanctions, and that its products do not originate in breach of sanctions or export controls. The Provider may refuse or stop the service to comply with such rules.

21. Notices, assignment and order of precedence

21.1

Notices are given by email to info@gdprrepresentative.com and to the email address of the Client recorded in the Designation. The Client may not assign this Agreement without the Provider’s consent.

21.2

This Agreement consists of the Designation, these EUDR Authorised Representative Terms and Conditions with their Schedules and, for matters they do not address, the general Services Agreement. In case of conflict, the Designation prevails, then these Terms, then the general Services Agreement.

22. Electronic signature

22.1

The parties agree that the Designation and this Agreement are concluded by electronic means. The electronic signature of the Client, recorded with date, time and IP address, and the acceptance of the Provider have the same effect as handwritten signatures.

23. Governing law and jurisdiction

23.1

This Agreement is governed by the law of the Czech Republic, and the courts of Prague have exclusive jurisdiction. The service is offered to businesses only.

Schedule 1 — Service levels

Item	Time
Review of the designation form (clause 3.2)	Within 1 Working Day
Registration / link in the Information System (clause 4.1)	Within 3 Working Days of acceptance and of receiving any authorisation the system requires from the Client
Check of Shipment Data and questions on gaps (clause 4.4)	Within 1 Working Day of receipt
Submission of a DDS with complete Shipment Data (clause 4.5)	Within 2 Working Days; same Working Day on a best-effort basis if received before 12:00 CET
Forwarding of an authority request (clause 4.8)	Within 2 Working Days
Risk-assessment record per Product (clause 4.2)	Within 10 Working Days of complete supply-chain information, then yearly

Schedule 2 — Shipment Data (Article 9 of the Regulation)

Client’s name, postal address, email address and EORI number, where applicable;
HS/CN code, free-text description (including trade name and, for wood, the common and full scientific name of the species) and quantity (net mass and, where applicable, supplementary unit or volume) of the Relevant Products;
country of production and, where applicable, parts of it;
geolocation of all plots of land where the Relevant Commodities were produced and the date or time range of production (for cattle, the establishments where the cattle were kept);
name, postal address and email address of the suppliers and of the business customers to whom the products are supplied;
adequately conclusive and verifiable information that the products are deforestation-free and that they were produced in accordance with the relevant legislation of the country of production;
where the Client relies on a DDS already submitted upstream, its reference and verification numbers;
the planned date of placing on the market or export and the customs office or courier, where known.

Schedule 3 — Plans and fees

Amounts in euros, excluding VAT. The prices shown on gdprrepresentative.com at the date of purchase prevail; the table below shows the current prices.

Plan	Products covered	Yearly	Monthly (12-month minimum)	Renewal
Current prices: see the EUDR page.

Additional Products beyond the largest Plan are charged per Product per year at the fee shown at the date of purchase. All Plans include unlimited due diligence statements for the Products covered, with no per-shipment fee.

Schedule 4 — Relevant Commodities and examples of Relevant Products (Annex I)

Indicative list for orientation only; Annex I to the Regulation, as amended, and the Combined Nomenclature prevail. Classification of the goods is the Client’s responsibility (clause 6.5).

Commodity	Examples of Relevant Products	Typical HS headings
Cattle	Live cattle, meat, hides and skins, leather	0102, 0201, 0202, 0206, 1602, 4101, 4104–4107
Cocoa	Cocoa beans, paste, butter, powder, chocolate	1801–1806
Coffee	Coffee, roasted or not, husks and skins	0901
Oil palm	Palm nuts and kernels, palm oil and its fractions, derived chemicals (e.g. glycerol, fatty acids)	1207 10, 1511, 1513 21–29, 2306 60, 2905 45, 2915 70, 3823, 3826
Rubber	Natural rubber, tyres, inner tubes, articles of vulcanised rubber	4001, 4005–4008, 4010–4013, 4015, 4016
Soya	Soya beans, flour, oil, oil-cake	1201, 1208 10, 1507, 2304
Wood	Logs, sawn wood, panels, pulp, paper and paperboard, printed products, wooden furniture, charcoal, wooden packaging used to carry other products when placed as a product in its own right	4401–4421, 47, 48, 49 (selected), 9401, 9403 (selected), 9406 10

Schedule 5 — Situations requiring prior agreement or excluded

products for which no geolocation can be obtained for all plots of land of production: no DDS can be submitted until it is available;
products from a country or area subject to sanctions, or from suppliers on a sanctions list;
goods already presented to customs without a DDS reference: the Provider will submit as soon as the Shipment Data are complete but cannot cure any prior non-compliance;
products outside Annex I (including, at the date of these Terms, packaging used solely to support, protect or carry another product and goods consisting entirely of recovered material): no DDS is required and none is submitted, unless the Client instructs otherwise in writing;
volumes exceeding 500 DDS per month or more than 200 plots per DDS: the Provider may ask for data in a bulk format agreed with the Client.

Schedule 6 — Authorised Representative details

Europe Services, SE · Na Čečeličce 425/4, Smíchov, 150 00 Praha 5, Czech Republic · IČO 03571785 · VAT CZ03571785 · Municipal Court in Prague, H 1486 · info@gdprrepresentative.com · +420 775 397 884 · Contact person: Legal Department - Omar Soligo. Public verification of each Designation: gdprrepresentative.com/verify.php?code=E06-…

Schedule 7 — Key dates of the Regulation (for information)

Date	Event
29 June 2023	Entry into force of Regulation (EU) 2023/1115
30 December 2026	Application to medium and large operators and traders, as postponed
30 June 2027	Application to micro and small operators, as postponed

Dates as known at the version date of these Terms. Any later change made by the EU legislator applies automatically and the Provider informs Clients under clause 19.

Questions on these Terms: info@gdprrepresentative.com · +420 775 397 884