What an authorised representative is
Article 2(22) defines it as a natural or legal person established in the EU that has received a written mandate from an operator or trader to act on its behalf. Article 6 allows it to submit the DDS for its client. If the authority asks, it has to show a copy of the mandate.
What does not change is who is liable. The operator remains responsible for the product complying, even if someone else submitted the DDS. For the importer, it is a way to hand over the work, not the responsibility.
It is not the same as customs representation
Being a client's customs representative (direct or indirect, under the Union Customs Code) does not make you its representative for the EUDR. They are two different roles with two different documents. You need a separate EUDR mandate, although you can sign it at the same time as the customs one.
In practice the two jobs meet: the DDS reference number has to go on the customs declaration (in Spain, the DUA). If you do both, the number goes from TRACES to the customs declaration without anyone copying it out of an email.
How it works in TRACES
When you register your company in the EUDR information system, you request the authorised representative role. TRACES distinguishes between representing an operator and representing a trader. In every DDS you submit under that role you have to identify the actual operator, with its name and country. If that is missing, TRACES rejects the statement.
The rest of the DDS is the same as any operator's: product, quantity, country of production and geolocation. The EORI that counts for the import is the operator's, not yours. The step by step is in the guide on how to submit a DDS.
What to put in the mandate
The Regulation requires the mandate to be in writing but gives no template. A mandate that works in practice covers at least the following (this is not legal advice; review it with your lawyer):
- Who the operator is and who the representative is, with tax ID (in Spain, the NIF) and EORI.
- What it covers: commodities or CN codes, the period, and whether it includes amending and withdrawing DDSs.
- What information the operator provides and when: suppliers, geolocation, risk assessment.
- That the risk decision belongs to the operator, and how the operator communicates it to you.
- Who keeps the records for 5 years and how they are accessed during a check.
- What happens if information is missing at the time of clearance.
What a forwarder can and cannot do
You can collect data from suppliers, validate GeoJSON files, prepare and submit the DDS, carry the number over to the customs declaration and keep the file. Many small importers will need this service, because they have no one who knows TRACES.
What you should avoid is the forwarder deciding on its own that the risk is negligible. That conclusion belongs to the operator. The sensible approach is a mandate that states clearly that you submit with the assessment the client gives you, or with one you prepare and the client approves.
How to organise it with many clients
A forwarder in Valencia with 40 coffee, cocoa and wood importers has 40 different operators, each with its own suppliers and plots, and hundreds of DDSs a year. With the TRACES web form, that means copying and pasting all day.
Sourevo is built for that case: one organisation managing several operators, with a portal where each client's suppliers upload their plots, and DDSs submitted through the TRACES API under the authorised representative role. If you want to see it with one of your own cases, write to us.
Frequently asked questions
- Does the representative have to be in Spain?
- It has to be established in the EU. It does not have to be in the same country as the operator.
- Can I represent an exporter from outside the EU?
- The DDS for an import is submitted by the operator that places the product on the EU market, which is the importer established here. If the party making the product available is not established in the EU, Article 7 moves operator status to the first person established in the EU that makes the product available.
- Do I need a separate mandate for each operation?
- The Regulation only requires the mandate to be in writing. It does not ask for one per operation, so one mandate per client that sets out what it covers and for how long is enough in most cases.
- Can I charge for submitting DDSs?
- Yes. It is a service like customs brokerage, and the Regulation says nothing about its price. What you charge does not change who is responsible: that is still the operator.
- Does anything change for micro and small enterprises?
- Only the date: many of them start on 30 June 2027, except for EUTR wood. They are the ones most likely to delegate. The dates are in the deadlines guide.