Can One Authorised Representative Cover Both GPSR and EUDR?
If you sell products in the EU, you have probably already dealt with the question of EU-established representatives. GPSR introduced a mandatory requirement for non-EU brands to have an economic operator established in the EU who is responsible for their products — without this, you cannot legally place them on the market.
Now the EU Deforestation Regulation (EUDR) is introducing its own version of the same concept. And the question a lot of brands are asking is: do I need a separate authorised representative for EUDR, or can the one I already have cover both?
The short answer is that it depends on how your current arrangement is set up. This post explains how the representative role works under each regulation, where they overlap, and what to check before assuming you are covered.
What Is an Authorised Representative Under GPSR?
Under GPSR, two related but distinct concepts need to be understood.
The first is the “responsible person” requirement. Under Article 16 of GPSR (which incorporates Article 4 of Regulation (EU) 2019/1020), no product may be placed on the EU market unless there is an economic operator established in the EU who can be held accountable by market surveillance authorities. This is the hard legal obligation for non-EU brands. The responsible person must be identified on the product or its packaging, and they take on specific duties to check that the product meets documentation and labelling requirements.
The second is the authorised representative, which is a separate and optional appointment under Article 9. A manufacturer may — but is not required to — appoint an authorised representative by means of a written mandate. The AR and the responsible person can be the same entity, and in practice many service providers combine both roles, but they are legally distinct.
The Article 9 mandate must allow the AR to perform at least the following tasks:
- Providing a market surveillance authority, upon request, with all information and documentation necessary to demonstrate the safety of the product
- Informing the manufacturer if the AR has reason to believe a product is dangerous
- Informing competent national authorities about corrective actions taken to eliminate risks posed by products covered by the mandate, via the Safety Business Gateway
- Cooperating with competent authorities on any action taken to eliminate risks
It is worth being clear about what the AR role under Article 9 does not include. Holding technical documentation, registering products, and ensuring labelling and traceability compliance are obligations that fall on the manufacturer or the responsible person — not on the AR. The AR’s role is primarily to act as a communication and coordination point with authorities, within the scope of the tasks delegated by the manufacturer.
What Is an Authorised Representative Under the EUDR?
The EUDR introduces a different AR role. Under Article 6 of the Regulation, an operator or trader may mandate an authorised representative to submit the due diligence statement on their behalf.
The EUDR AR must be:
- Established in the EU (Article 2(22) defines the AR as any natural or legal person established in the Union who has received a written mandate from an operator or trader)
- In possession of a written mandate from the operator or trader
- Able to provide a copy of that mandate to competent authorities on request
- Registered in the EUDR Information System in order to submit due diligence statements on behalf of the operators they represent
One authorised representative can act for multiple operators, as long as each mandate is properly documented and each operator is individually identified when statements are submitted.
One important difference from GPSR: under the EUDR, appointing an AR does not transfer compliance responsibility. The operator or trader still retains responsibility for whether the products actually comply with the deforestation-free and legality requirements of Article 3. The AR handles the submission of the due diligence statement, but accountability for the underlying due diligence remains with the operator.
Where the Two Roles Overlap
Both roles require EU establishment, a formal written mandate, and a clear record of which products and operators are being represented. In that sense, the administrative foundation is similar.
If your current GPSR responsible person or authorised representative is already set up to handle documentation, regulatory registrations, and authority correspondence on your behalf, they may be well placed to also take on the EUDR AR role. But there are a few things to check:
- Does your existing mandate cover EUDR submissions specifically, or is it limited to GPSR obligations? Mandates need to be explicit about scope.
- Is your representative registered or able to register in the EUDR Information System? This is a separate system from the Safety Business Gateway used for GPSR.
- Does your representative have the capability to handle due diligence statement submissions, including geolocation data and the traceability documentation the EUDR requires?
If the answer to any of those is no, you either need to extend your existing arrangement or look at a separate EUDR representative.
Where the Two Roles Are Different
The scope of what each representative actually does day to day is quite different.
Your GPSR responsible person or AR is primarily dealing with product documentation, safety communications, and market surveillance. Their work is largely about the product itself: what it is, what it does, and whether it is safe.
Your EUDR AR is dealing with supply chain documentation: where the commodities in your product came from, whether those plots of land were deforestation-free after 31 December 2020, and submitting the formal due diligence statement to the EU’s information system before your products are placed on the market.
What About Micro and Small Businesses?
The EUDR has a specific provision for micro operators and natural persons. Under Article 6(3), an operator that is a natural person or a microenterprise may mandate the next operator or trader further down the supply chain to act as their authorised representative. This is permitted only if the appointed operator or trader is not itself a natural person or microenterprise. In such cases, the operator remains responsible for compliance with the deforestation-free and legality requirements, and must communicate to the next operator or trader all information necessary to confirm that due diligence was exercised.
On deadlines: the original EUDR set an application date of 30 December 2024, but this was amended by Regulation (EU) 2024/3234, adopted on 19 December 2024. Under the amended Article 38, the substantive obligations now apply from:
- 30 December 2025 for large operators and traders
- 30 June 2027 for operators and traders that were established as micro-undertakings or small undertakings as of 31 December 2020 (with the exception of products already covered by the EU Timber Regulation)
Do You Need One AR or Two?
There is no rule that says you need separate representatives for GPSR and EUDR. One company can legally hold both mandates and act in both capacities, as long as they are properly set up for each.
In practice, the question is whether your current representative has the capability and the systems to handle EUDR work. Ask them:
- Are they registered or planning to register in the EUDR Information System?
- Do they have experience with supply chain due diligence and deforestation-free documentation?
- Can they handle geolocation data and due diligence statement submissions?
- Is their mandate from you broad enough to cover EUDR obligations, or does it need updating?
If they can handle both, consolidating with one representative keeps things simpler and reduces the number of relationships you need to manage. If they cannot, it is better to know now than to find out in December 2025.
The EUDR Information System was established under Commission Implementing Regulation (EU) 2024/3084, published in December 2024, and is already operational. Operators need to register and submit statements before products are placed on the market. If you are in scope, there is no benefit to waiting.
How Euverify Can Help
Euverify provides authorised representative and responsible person services for brands and manufacturers selling into the EU and UK. We work with businesses on GPSR compliance,CE and UKCA marking, REACH obligations, and EU and UK market access.
If you are trying to work out what your EUDR obligations are and how they fit with your existing compliance setup, we can help you review your current arrangements and identify any gaps.
Find out more about our EU and UK Authorised Representative Services.
