Understanding the role of Authorised Representatives under the EUDR

When it comes to the EU Deforestation Regulation (EUDR), most of the attention rightly focuses on its core requirements: traceability, due diligence, and risk assessment. But there’s a lesser-known element that may be especially relevant in certain cases, such as when managing multiple entities or reducing administrative burden: the role of the Authorised Representative.

While not central to the EUDR’s core compliance obligations, the Authorised Representative can serve as a practical tool for managing how certain regulatory steps are carried out. Understanding its role and its limits can help operators make informed decisions. 

Let’s take a closer look at what an Authorised Representative is and when it might be useful. This topic has come up frequently in discussions with operators seeking clarity on their options under the EUDR.

What is an Authorised Representative?

An Authorised Representative is any person residing in the EU who has received a written mandate to submit a due diligence statement (DDS) on behalf of an operator. Their role is limited to submitting the DDS via the EU’s Information System, TRACES.

Who can use an Authorised Representative?

Under Article 6(1) of the EUDR, both operators and large traders may appoint an Authorised Representative to submit a DDS on their behalf. For simplicity, we refer to both roles collectively as “operators” throughout this article, unless a distinction is necessary.

Appointing an Authorised Representative is generally voluntary. However, there is one specific situation (explained later) where using an Authorised Representative may effectively become necessary for operators wishing to continue placing products on the market.

In most cases, operators choose to appoint an Authorised Representative to delegate the task of submitting the DDS, while retaining full legal responsibility for compliance.

What are the limitations of the Authorised Representative?

The Authorised Representative’s role is purely administrative. They are not involved in verifying supply chains, checking geolocation data, or assessing risk. All due diligence obligations—including implementing risk mitigation and ensuring product compliance—remain solely with the operator.

The distinction is crucial: the Authorised Representative facilitates one task (submission of DDS) but does not change any of the operator’s other responsibilities under the law.

When does appointing an Authorised Representative make sense?

There are a few practical reasons why an operator may choose to appoint an Authorised Representative. These include, among others:

• Managing multiple entities: In a group with several EU-based legal entities, a central one (such as the headquarters) may act as the Authorised Representative for others to coordinate DDS submissions.
• Reducing administrative burden: Operators handling large volumes of DDS may prefer to delegate the task to an external service provider acting as an Authorised Representative.

In both cases, the Authorised Representative’s function remains the same—submitting DDSs—while the operator continues to oversee and control all underlying processes.

When not to appoint an Authorised Representative

Appointing an Authorised Representative is not a way to reduce your obligations. It does not shift legal responsibilities. Operators still need to perform due diligence, confirm product compliance, and retain documentation for five years. 

If an operator is hoping the Authorised Representative will handle the heavy lifting, they should reconsider. The Authorised Representative cannot conduct risk analysis or decide whether a product can enter the EU market. That remains the operator’s responsibility.

Options for natural persons and microenterprises

Under Article 6(3) of the EUDR, operators that are natural persons or microenterprises may mandate the next operator in the supply chain—provided that it is not also a natural person or microenterprise—to submit the DDS on their behalf. The next operator cannot place the relevant products on the market or export them until the DDS has been submitted.

In this scenario:

• The next operator must act as the Authorised Representative if they wish to place relevant products from the operator who is a natural person or microenterprise on the market, and
• The operator that is a natural person or microenterprise retains legal responsibility for the products and must provide the necessary information to complete the DDS.

If the next operator or trader is unable or unwilling to submit the DDS, this may prevent the relevant products from being placed on the market or exported, as a DDS must be submitted before market access is permitted under the EUDR.

What’s the process for becoming or appointing an Authorised Representative?

There are two essential steps:

1. Register in the EU Information System (TRACES)

   Both the operator and the Authorised Representative must register in the Information System, TRACES. While the operator will register under the role “EUDR Operator” (or “EUDR Trader”), the Authorised Representative will register under “EUDR Authorised Representative”. Once linked to the operator’s account, they can submit DDSs. However, all data remains under the operator’s record, not the Authorised Representative’s, ensuring transparency and control remain with the responsible party.

   For information and instructions on how to register in TRACES and navigate the platform, visit the European Commission’s official website.

    

2. Issue a written mandate

   The operator must formally appoint the Authorised Representative through a written mandate. While the EUDR doesn’t prescribe a format, the mandate must confirm the appointment and be available for inspection by competent authorities. It may also need to be translated into an official EU language or, where applicable, into the official language of the Member State where the DDS is submitted.

   Tip: Use our free Preferred by Nature EUDR Authorised Representative Written Mandate Template, available through the Preferred by Nature Due Diligence Toolkit (sign-up required), to create this document.

    

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The Authorised Representative is not a shortcut or legal shield, but it can offer a helpful way to manage the submission of DDSs, especially for operators with multiple legal entities or high submission volumes. When used thoughtfully, this role can improve administrative and operational efficiency. But it must be accompanied by clear internal processes and a firm understanding that legal responsibilities always remain with the operator.

In cases where an Authorised Representative is mandatory (under Article 6(3)), it’s essential to ensure that both parties understand and fulfil their obligations. Our template includes a separate notification form for these specific cases.

Need more support? Our Due Diligence Toolkit also includes additional templates, guidance and practical tools – or you can get in touch with our team.