EUDR Authorised Representative  

As companies navigate the European Union Deforestation Regulation (EUDR), the concept of an Authorised Representative (AR) is gaining attention, especially for businesses operating across borders. While it offers flexibility, it also raises questions about responsibility, liability, and compliance. 

What is an Authorised Representative under EUDR? 

An Authorised Representative (AR) is a natural or legal person established in the EU who is appointed by an operator or trader to act on their behalf for specific EUDR obligations. 

This is particularly relevant for: 

• Non-EU companies exporting to the EU 

• Businesses that want to delegate compliance-related tasks 

The AR acts as a compliance interface with EU authorities. 

Why would a company appoint an Authorised Representative? 

There are several reasons companies choose to appoint an AR: 

• To simplify compliance management within the EU 

• To ensure alignment with local regulatory expectations 

• To handle Due Diligence Statement (DDS) submissions 

• To streamline communication with competent authorities 

For non-EU operators, having an EU-based representative can be critical for market access. 

What responsibilities can an Authorised Representative handle? 

An AR can be mandated to perform specific tasks, such as: 

• Submitting Due Diligence Statements (DDS) 

• Managing compliance documentation 

• Acting as a point of contact for audits and inspections 

• Maintaining records required under EUDR 

However, the scope of responsibility depends on the written mandate between the operator and the AR. 

Does appointing an AR transfer legal responsibility? 

No, and this is a critical point. 

Even when an Authorised Representative is appointed: 

• The operator remains ultimately responsible for compliance 

• Liability for non-compliance cannot be fully delegated 

The AR supports execution, but accountability stays with the operator placing products on the EU market. 

Who can act as an Authorised Representative? 

To qualify, an AR must: 

• Be established within the European Union 

• Have the capability to manage compliance obligations 

• Be formally appointed through a written mandate 

This could include: 

• Compliance service providers 

• EU-based subsidiaries 

• Specialized regulatory consultants 

What are the risks of relying on an Authorised Representative? 

While ARs offer operational convenience, they also introduce risks: 

• Over-reliance on third parties for compliance execution 

• Lack of visibility into actual supply chain data 

• Potential misalignment between operator data and AR submissions 

• Delays or errors in DDS submissions 

If the underlying data is flawed, the AR cannot fix compliance it can only submit what it receives. 

How should companies approach the use of ARs under EUDR? 

Companies should treat ARs as execution partners, not compliance owners. 

Best practices include: 

• Maintaining direct control over supply chain data 

• Ensuring traceability systems are internally robust 

• Regularly validating data before AR submission 

• Clearly defining roles and responsibilities in the mandate 

In essence, compliance must be built within your systems, not outsourced entirely. 

How does traceability support Authorised Representatives? 

Traceability platforms make it easier for both operators and ARs to: 

• Access structured, audit-ready data 

• Validate geolocation and supplier information 

• Ensure DDS submissions are accurate and complete 

• Reduce dependency on manual data exchange 

This creates a single source of truth, minimizing errors and improving compliance confidence. 

Frequently Asked Questions (FAQ’s)

Final Takeaway 

The Authorised Representative role under EUDR offers flexibility but not a shortcut. 

It helps streamline compliance execution, especially across borders, but does not replace the need for strong internal systems and traceability. 

Because in the end, compliance isn’t about who submits the data. 

It’s about how reliable that data is.