Guide to EUDR Authorised Representatives

The EU Deforestation Regulation (EU) 2023/1115 states that EU based authorised representatives can submit due diligence statements or simplified declarations on behalf of an operator.

In this guide, we explain who can act as an authorised representative. We also provide a list of companies offering EUDR authorised representative solutions.

Key points

• Operators can appoint an authorised representative
• The authorised representative must be located in the EU
• The authorised representative can submit due diligence statements
• The authorised representative can submit simplified declarations

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What are EUDR authorised representatives?

The EUDR defines an authorised representative as an entity established within the European Union which can perform certain tasks on behalf of the operator.

‘authorised representative’ means any natural or legal person established in the Union who, in accordance with Article 6, has received a written mandate from an operator to act on its behalf in relation to specified tasks with regard to the operator’s obligations under this Regulation;

Note that an operator is generally the first entity to introduce a product covered by the EUDR on the EU market. An operator can be established inside or outside of the EU.

Which tasks can be performed by an EUDR authorised representative?

Article 6 of the EUDR stipulates that an authorised representative can carry out the following tasks:

✅ Submit a due diligence statement on behalf of an operator

✅ Submit a simplified declaration on behalf of a micro or small primary operator

It is also stated that the authorised representative must be able to submit a copy of the mandate signed with the operator if requested.

What information is submitted by the EUDR authorised representative?

As mentioned, the EUDR authorised representative primarily submits the information required in either a due diligence statement or a simplified declaration.

The table below shows what must be included in both:

Due diligence statement	Simplified declaration

Who can act as an EUDR authorised representative?

The definition states that any entity in the EU with a written mandate from an operator can act as an authorised representative.

Article 6(3) also clarifies that a downstream operator or trader can act as an authorised representative, but only if the operator is a natural person or microenterprise.

3. An operator that is a natural person or a microenterprise may mandate the next downstream operator or trader further down the supply chain that is not a natural person or a microenterprise to act as an authorised representative. Such next downstream operator or trader further down the supply chain shall not place or make available on the market or export relevant products without submitting the due diligence statement pursuant to Article 4(2) on behalf of that operator or, in the case of a micro or small primary operator, without submitting a simplified declaration on behalf of the micro or small primary operator in the information system referred to in Article 33. In such cases, the operator that is a natural person or a microenterprise shall retain responsibility for compliance of the relevant product with Article 3.

The scenario described under Article 6(3) is likely intended to reduce the burden on, for example, a small forest owner.

Instead, their customer (i.e., a furniture factory) must submit the due diligence statement or simplified declaration.

But this should not be understood as allowing any operator to freely push this mandate on their customers.

List of EUDR authorised representatives

I could only find a few companies that claim to offer authorised representative services within the scope of the EUDR. Let me know if you want to see other companies added to this list.

24 Hour AR

Based in the Netherlands, 24 Hour AR is specialised in providing EU authorised representative solutions for various products.

They also state that they can act as an authorised representative under the EUDR.

Peterson Solutions

Peterson Solutions, which have served customers in more than 80 countries for over a century, provides solutions related to data submission via the TRACES system.

How much does it cost?

The cost depends entirely on the number of products, and the number of due diligence statements or simplified declarations that must be submitted by the authorised representative.

There is no, as far as I am aware, standardised flat rate cost.