Glossary
Glossary term

authorised representative

A cross-regulation actor term for a person or entity mandated to act on behalf of another economic actor under specified legal conditions.

4 official sourcesrelated_but_not_identical

What does authorised representative mean?

Authorised representative appears across multiple EU frameworks, but the role should not be treated as automatically identical everywhere. The shared idea is delegated action on behalf of another party, while the scope of that mandate depends on the source.

Official definitions by source

ESPR

Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products

any natural or legal person established in the Union that has received a written mandate from the manufacturer to act on the manufacturer’s behalf in relation to specified tasks with regard to the manufacturer’s obligations under this Regulation;

Reference: Article 2, point 43

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EU Battery Regulation

Regulation (EU) 2023/1542 concerning batteries and waste batteries

any natural or legal person established in the Union who has received a written mandate from a manufacturer to act on its behalf in relation to specified tasks with regard to the manufacturer’s obligations under Chapters IV and VI;

Reference: Article 3, point 63

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EUDR

Regulation (EU) 2023/1115 on deforestation-free products

any natural or legal person established in the Union who, in accordance with Article 6, has received a written mandate from an operator or from a trader to act on its behalf in relation to specified tasks with regard to the operator’s or the trader’s obligations under this Regulation;

Reference: Article 2, point 22

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CSDDD

Directive (EU) 2024/1760 on corporate sustainability due diligence

a natural or legal person resident or established in the Union that has a mandate from a company within the meaning of point (a)(ii) to act on its behalf in relation to compliance with that company’s obligations pursuant to this Directive;

Reference: Article 3, point k

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Definition status

The definitions from different sources are related but not legally interchangeable — check which source applies to your specific regulatory obligation before relying on a definition.

How the definitions differ

Across all four regulations, an authorised representative is an EU-established entity holding a written mandate from a non-EU principal. The key differences are in scope of mandate. Under ESPR, the mandate covers manufacturer obligations under the Regulation, primarily technical documentation, conformity, and market-surveillance cooperation. Under the EU Battery Regulation, the mandate is explicitly limited to Chapters IV (conformity assessment) and VI (due diligence), and it does not cover EPR/producer-responsibility obligations, which have their own separate authorised representative for EPR role. Under EUDR, the mandate may be given by either an operator or a trader and covers due-diligence-statement obligations. Under CSDDD, the mandate is for compliance with the Directive's due-diligence obligations by a non-EU company in scope of CSDDD. These are not interchangeable mandates, so a company cannot use a single authorised representative appointment to satisfy all four regulations simultaneously.

Practical application

This term matters when a company relies on a representative to handle declarations, documentation, or market-access obligations. Teams need to know exactly which functions may be delegated and which remain with the original actor.

Minespider commentary

For Minespider, authorised representative is a source-aware role term. The important question is not just who the representative is, but which legal tasks the source actually allows that representative to perform.

Common confusions

  • Assuming one authorised representative appointment covers obligations under all EU regulations — each regulation requires a separate mandate scoped to that regulation's obligations.
  • Confusing the EU Battery Regulation's "authorised representative" (Chapters IV and VI) with the "authorised representative for extended producer responsibility" (Article 57) — these are two distinct roles with different functions and legal consequences.
  • Assuming the representative becomes a co-liable party in all cases — the extent of representative liability depends on the regulation; under CSDDD, for example, the representative supports compliance but the underlying company remains the primary obligated entity.
  • Overlooking the written mandate requirement — an informal arrangement does not create valid regulatory authorization; the mandate must be in writing and must specify the scope of delegated tasks.