Can you submit EUDR declarations on behalf of your clients?

Which part of the work are you taking on?

A client might ask you to collect supplier evidence, check a spreadsheet, prepare a declaration or press Submit. Those are different assignments. Describe them separately in your engagement so the client and your delivery team know where the handover happens.

Preparation support

Your team organises records or prepares fields. The client retains the agreed review and filing steps.

Authorised representation

Your organisation has a written mandate to act for the operator on specified tasks, including the agreed declaration submission.

Software or integration

A system moves and validates data. Its technical access is separate from the authority of the people or organisation using it.

One firm can provide more than one of these services. A software subscription or an invitation to a workspace does not, by itself, document a representative appointment. Start by identifying the client’s role in the transaction: a downstream record-keeping assignment should not automatically become a new-DDS filing service.

Who can be an EUDR authorised representative?

The Commission’s roles guidance includes EU-established independent service providers, associations and members of a company group among possible representatives. Appointment is optional. Representatives register separately from operators in the Information System.

The role belongs to the appointed person or legal entity. When several consultants work on a client account, your internal permissions should reflect that appointment: which team members prepare records, which review them and which may carry out the authorised action. A team member joining the project should not silently expand the service you agreed with the client.

What should the mandate and engagement cover?

The legal starting point is a written mandate for specified tasks. Article 6 also requires the representative to supply a copy on request, with the language requirements set out in Article 6(2). Have the document reviewed for the actual arrangement; the points below are operational questions, not a legally complete form.

• Who is appointing whom? Record the exact legal entities, not just a trading name or the consultant’s email address.
• What work is covered? Specify the declaration route and the tasks your team will perform. Agree separately how corrections, withdrawal requests and authority enquiries will be handled.
• Who makes the decisions? Identify the client’s evidence owner and the person authorised to approve the information for filing.
• When does the arrangement apply? Record its agreed start, any limits and how changes or termination reach the delivery team.
• What happens to the records? Agree where the mandate, approvals, evidence and submission results are kept, and how the client receives them.

Turn those answers into a client-onboarding record that the team can check before work enters the submission queue. Keep the signed authority accessible without circulating it with every supplier file.

Does outsourcing the filing transfer responsibility?

Article 6 keeps product-compliance responsibility with the operator. That is not a promise that a service provider has no contractual or other legal exposure. Agree the service obligations and escalation process with appropriate advice.

In practice, your team needs a clear answer when the evidence is incomplete. Who contacts the supplier? Who decides whether the outstanding issue has been resolved? Who tells the client that filing is on hold? Preparing the due diligence evidence and transmitting the final fields are connected work, but they are not interchangeable.

Can the same team serve several operators?

Yes, but keep each appointment and client record distinct. The Commission describes group members appointing one representative; its multi-operator API guidance also covers service providers acting for several operators. That technical mechanism selects an operator context; it is not a replacement for the legal mandate.

Use this separation throughout the work: client identity, authority, evidence, approval, request and returned result. A shared queue is useful for workload management. A shared, ambiguous client identity is not.

A fictional example: two clients, the same lot reference

A consultancy receives a file labelled “LOT-24” from a coffee importer and another with the same label from a timber importer. The coffee file is approved; the timber file is awaiting a corrected location. Searching by lot number alone could expose the wrong approval or send the wrong result back to a client.

Treat each record as belonging to its legal entity from intake onwards. Before filing, show the reviewer the client, product, input version and authority being used. After filing, attach the issued reference and verification numbers to that same record. Never infer the client from the filename alone.

Keep system access separate from the mandate

The Commission’s access guide recommends testing in acceptance before repeating setup for production. It also states that authentication keys are private. Follow the supported registration process rather than asking clients to email passwords or copying a colleague’s account.

For an integration, the TRACES API operating design needs to keep the selected client explicit on every action. Verify the supported multi-operator setup with EUDR support before relying on it; the current access guide contains both a single-operator user warning and a later multi-operator section.

When an engagement ends, check pending work before removing access. Assign ownership of open corrections and uncertain submissions, deliver the agreed records and prevent new work from using the expired arrangement. These are recommended service controls, not a claim that ending a contract removes previously filed statements.

Build the workflow around your representative service

If your team is moving between client spreadsheets, approvals and the filing portal, we can help scope a multi-client EUDR workflow around those handovers. Bring one redacted client journey, including who approves and who is authorised to act.

InvariTech provides engineering support. This page does not offer to appoint us as your authorised representative or transfer your client’s compliance decisions to us.