Authorised Representatives under the EUDR: Roles, Limits and Liability

With the EU Deforestation Regulation (EUDR) applying from 30th December 2026, one question has come up in almost every webinar and customer conversation we have had this year: can someone else submit our due diligence statements for us? The answer is yes, through an Authorised Representative, though the role is narrower than many businesses assume.

Authorised Representatives can take a real administrative load off operators and traders, particularly those clearing high volumes of goods into the EU or working to tight lead times. They can also be a practical route for non-EU suppliers with an EU presence, groups of companies and freight forwarders looking to support their customers. What they cannot do is take on an operator's legal responsibility, and that distinction is where most of the confusion lies.

In this post, we answer the questions our customers have been asking us most often, including what an Authorised Representative is and is not, what is required to become one, where liability sits, and whether Interu can act as one.

The basics

1. What is an Authorised Representative?

Under the EUDR, operators and traders can mandate an Authorised Representative to submit due diligence statements (DDS) to the EUDR Information System (TRACES) on their behalf. The Authorised Representative, which must be established in the EU, acts under a written mandate from the company it represents, and is registered in TRACES in that role.

The role is essentially administrative. It is most useful for businesses that place large volumes of goods on the EU market and lack the internal resources to manage every submission, or where short lead times mean statements need to be filed quickly and close to the point of import.

2. What is an Authorised Representative not?

This is where most of the confusion lies, so it is worth being clear about the limits of the role. An Authorised Representative:

• Does not take on legal liability. Responsibility for compliance stays with the operator or trader it represents, at all times.
• Does not replace the operator's due diligence. The operator remains responsible for gathering information, assessing and mitigating risk, and reaching its own conclusion that products are deforestation-free and legally produced. The Authorised Representative submits the statement which records that work.
• Cannot be based outside the EU. A non-EU entity cannot take on the role.
• Is not mandatory. Operators can register and submit their own statements, and many will.
• Is not the same as a customs representative. A freight forwarder or customs agent only becomes an Authorised Representative if it is mandated and registered as one.

Becoming an Authorised Representative

1. What is required to be one?

The Commission's FAQs (5.2 and 5.2.1) set out two requirements. The Authorised Representative must be established in the EU, and it must hold a written mandate from each operator or trader it represents. It also needs to be registered in TRACES with the Authorised Representative role (FAQ 5.17), so that it can submit statements naming the company it is acting for.

In practice, it is sensible for the mandate to set out which products, supply chains or entities it covers, how due diligence information will be passed to the representative, and how quickly reference and verification numbers will be returned for use on customs declarations.

2. Does the company being represented need its own TRACES account?

FAQ 5.17 says operators must register before submitting statements, or can instead use the services of an Authorised Representative who is registered as such. The FAQs do not spell out whether the represented company also needs an account of its own, and industry guidance differs on this point, with some sources advising that both parties register and link their accounts.

Given that uncertainty, we recommend checking with your Authorised Representative and the relevant Competent Authority before your first shipment, and testing the flow on the TRACES training platform.

3. Can one Authorised Representative act for several companies, or one company use several?

The FAQs allow for both. FAQ 3.13 confirms that an Authorised Representative can use a single account to submit and manage statements on behalf of all the entities it represents. A business can also hold several roles in TRACES at once, including operator and Authorised Representative (FAQ 7.29), and an operator is not limited to one Authorised Representative. A company could, for example, use both an EU sister company and a third-party provider, depending on which suits each flow of goods.

Liability and who can act

1. Who is liable if something goes wrong?

Legal liability always remains with the operator or trader. Appointing an Authorised Representative changes who submits the statement in TRACES, and leaves the question of who answers to the Competent Authority exactly where it was.

If a Competent Authority investigates, the operator will be expected to explain its own due diligence system: its methodology, how it reached its conclusions and how its risk assessment and mitigation work. That explanation cannot be handed to an Authorised Representative or to a third-party platform, and if due diligence is found to be lacking, it is the operator that faces penalties.

2. Can a non-EU supplier act as an Authorised Representative?

A non-EU supplier can take on the role through an EU-established entity, such as a subsidiary or sister company. A supplier with an EU-registered business can use that business as an Authorised Representative for its EU customers, taking on the paperwork of submitting statements so the customer does not need to file its own. The customer, as the operator placing the goods on the market, still carries legal liability.

This is a different arrangement from a supplier acting as a non-EU operator, for example when selling on DDP terms. In that case, the supplier submits its own statement and its EU customer must also submit one.

3. Can a subsidiary or sister company act for the rest of the group?

As we understand it, they can. Because a business can hold both operator and Authorised Representative roles in TRACES, an operator that is part of a group should be able to submit statements on behalf of other EU entities in that group. This can centralise submissions in one team without changing which entity is legally responsible for each consignment.

4. Can freight forwarders or due diligence providers act as one?

They can, provided they are established in the EU and hold a written mandate from the company they represent. Logistics providers (such as freight forwarders) who are only moving goods, and customs agents have no EUDR obligations of their own (FAQ 2.1). However, both types of organisation can take on the Authorised Representative role. It's important to understand for EUDR that a customs representative is not the same as an Authorised Representative. Where lead times are short, this can reduce the back and forth of reference numbers, as the party preparing the customs declaration also submits the statement it needs.

Specialist due diligence providers can do the same. In every case, liability for any non-compliance remains with the client.

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If you are weighing up whether an Authorised Representative is right for your business, or how to set one up in Interu, get in touch with our team. We are always happy to talk through your specific situation.

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