Operator, Downstream Operator or Trader? EUDR Roles and Who Carries Which Obligation

The EU Deforestation Regulation (OJ L 150, 9.6.2023, p. 206) has been in force since 29 June 2023.

The EU Deforestation Regulation covers products of seven commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood), and the role decides which rules a company carries. An operator submits a due diligence statement (DDS) before placing or export (Article 4(2)); downstream operators and traders submit none and keep supplier and customer information (Article 5(3)). The eight role pages in Table 1 cover each role and special case.

Table 1. The 8 EUDR role pages

What Are the Four EUDR Roles Under Regulation (EU) 2023/1115?

An operator places relevant products on the market or exports them, a micro or small primary operator produces its own commodities in a low-risk country, a downstream operator uses only covered inputs, and a trader makes products available (Article 2(15), 2(15a), 2(15b) and 2(17)). Table 2 summarises the four definitions.

Table 2. The four EUDR roles (summary of the consolidated text)

Definitions as consolidated on 18 September 2026; every Article 2 term is explained under EUDR definitions.

The operator role excludes downstream operators. Placing on the market means the first making available on the Union market (Article 2(16)).

The micro or small primary operator is a subset of operator in a low-risk country. Implementing Regulation (EU) 2025/1093 classifies 140 countries, all 27 Member States among them, as low risk and 4 as high risk (Belarus, North Korea, Myanmar, Russia); producers in standard-risk countries such as Brazil or Indonesia never qualify, non-EU producers in low-risk countries do (recital 7 of Regulation (EU) 2025/2650).

The downstream operator definition turns on the words "all of which": every relevant input must already be covered by a statement filed further up the chain.

The trader is the residual role; making available means any supply for distribution, consumption or use on the Union market in the course of a commercial activity (Article 2(18)).

An authorised representative is no fifth role but an agent established in the Union with a written mandate from an operator; since 26 December 2025 traders can no longer mandate one (Article 2(22)). Every article of Regulation (EU) 2023/1115 is explained in the consolidated text.

Operator vs Trader: How Do You Tell Which EUDR Role You Have?

The role follows the transaction, not the company: it is assessed for each relevant product (Guidance, section 2). "Upstream operator" and "first downstream operator or trader" are Commission working terms (Green Forum), not terms of the act. A role finder applies the tests per product; the EUDR Role Finder follows the order below.

Which Questions Decide Your EUDR Role, From Annex I to Company Size?

This guide orders the role decision into five questions taken from Article 2; the Commission prescribes no fixed sequence.

1. Annex I: Is the CN code listed in Annex I? Without it no role arises; see EUDR Annex I.
2. Commercial activity: Is the product for processing, distribution or own business use (Article 2(19))?
3. First placing or export: Does the company place the product first or export it uncovered? Then it is an operator (Article 2(15)).
4. Covered inputs: Is it made only from covered relevant products? Then it is a downstream operator (Article 2(15b)); a seller without processing is a trader (Article 2(17)).
5. Size and origin: Is the operator micro or small, in a low-risk country, placing its own production? Then it is a micro or small primary operator. An SME does not exceed at least two of three limits: balance sheet EUR 25,000,000, net turnover EUR 50,000,000, average employees 250 (Directive 2013/34/EU as amended by Delegated Directive (EU) 2023/2775, values on 31 December 2024).

Imports, Processing, Exports and Live Cattle: How Do the Role Tests Work?

For imports the Commission considers the operator to be the importer named in customs data element 13 04 000 000, for exports the exporter in 13 01 000 000, regardless of any change of ownership (Guidance, section 2(a)).

Any CN code change after the input was placed makes the seller a downstream operator, such as cocoa beans (1801) made into chocolate (1806) or green coffee 0901 11 00 roasted into 0901 21 00; resale without a code change is trading, and uncovered inputs make the processor an operator for them (FAQ Version 5 (April 2026), 3.1.1).

Exporting a product not yet placed makes the exporter an operator; exporting DDS-covered products makes it a downstream operator, which gives customs a TARIC certificate code instead of a reference number (Article 26(4); FAQ 5.6.1).

The first person placing live cattle is the operator and all later sellers are traders (COM(2026) 191, section 4.1.1); processing into meat makes a downstream operator (FAQ 1.26), as set out for EUDR and cattle.

Retailers are operators, downstream operators or traders depending on the product (FAQ 3.9).

Who Carries Which Obligation: Due Diligence, Statement, Registration and Records?

Operators exercise due diligence and submit a due diligence statement before placing or export (Article 4(1) and 4(2)); downstream operators and traders do neither and collect the Article 5(3) information instead. Table 3 sets out every obligation by role.

Table 3. Who carries which EUDR obligation

Articles 4, 4a, 5, 11, 12 and 16 as amended by Regulation (EU) 2025/2650.

Only the first downstream operator or trader, supplied directly by an operator, collects reference numbers or declaration identifiers, passively: it keeps what it receives and may presume in good faith that a supplier sending none is not an operator (FAQ 3.4 and 3.5). SMEs carry this duty too (recital 6 of Regulation (EU) 2025/2650).

SME operators exercise full due diligence and submit their own DDS, because Regulation (EU) 2025/2650 deleted Article 4(8) to (10). The first annual report of non-SME operators covers 2027 and is published after 30 December 2027 (FAQ 5.14).

What Did Regulation (EU) 2025/2650 Change in the Roles?

Regulation (EU) 2025/2650, in force since 26 December 2025, inserted the downstream operator and the micro or small primary operator and deleted the rule treating non-SME traders as non-SME operators. That rule sat in the original Article 5(1). Chapter 2 now bears the title "Obligations of operators, downstream operators and traders". The 2026 review is covered under EUDR simplification under Regulation (EU) 2025/2650.

Role Obligations on the EUDR Timeline: When Do They Apply?

The role obligations apply from 30 December 2026 (Article 38(2)); operators that are natural persons or micro or small undertakings established as such by 31 December 2024 apply them from 30 June 2027 (Article 38(3)); products in the Annex to Regulation (EU) No 995/2010 from 30 December 2026. The main date covers Articles 3 to 13, 16 to 24, 26, 31 and 32.

Products placed by a deferred micro or small operator before 30 June 2027, and products made entirely from them, stay outside EUDR obligations for downstream operators and traders, who keep evidence of the earlier placing (Guidance, section 3). Every date in force sits on the EUDR timeline.

Can One Company Hold Several EUDR Roles?

Yes: the Commission considers that one legal entity can be the operator for an import and the first downstream operator for the product made from it (FAQ 3.8). The same entity need not pass its own import DDS number on to itself.

A coffee roaster that imports green coffee files a DDS as operator for the import, then places the roasted coffee as downstream operator. A company can also be a micro or small primary operator for its own harvest and an ordinary operator for bought-in commodities, in the Commission's view (FAQ Version 5).

How Are Company Groups Treated Under the EUDR?

Each legal entity in a group is assessed on its own for role and size and needs its own EUDR Information System account (FAQ 3.13). Group thresholds play no part, and one member may act as authorised representative for the others. The obligation rests on the entity named in the DDS (FAQ 5.3), citing Case C-117/24 of the Court of Justice of 13 November 2025: under the EUTR, access to the parent company's due diligence system is not sufficient. Accounts follow Implementing Regulation (EU) 2024/3084 as amended by Implementing Regulation (EU) 2026/1565 (in force 17 July 2026).

Authorised Representatives, Customs Representatives and Logistics Providers: Who Is Covered?

An authorised representative is established in the Union, holds a written mandate from an operator to submit its statement or simplified declaration, and leaves the operator responsible (Article 2(22) and 6(1)). An operator that is a natural person or microenterprise may mandate the next downstream operator or trader that is not one (Article 6(3)), and a non-EU operator cannot act as authorised representative (FAQ 3.7).

A customs representative under Article 18 of the Union Customs Code is a different function (FAQ 3.15), and one authorised representative may act for several operators (FAQ 3.13 and 5.2.1).

Freight forwarders, customs representatives and other logistics providers hold no role while they do not place, make available or export products (Guidance, section 2(a); FAQ 2.10 and 3.15). The companies and transactions the EUDR covers are set out under companies and transactions covered by the EUDR scope.

Which Role Do Non-EU Suppliers and Online Sellers Have?

A producer or exporter outside the Union that sells to an EU importer has no EUDR obligation of its own; the importer is the operator and asks it for the Article 9 information (FAQ 3.10.2). Data-sharing bans in the producer country do not exempt it (FAQ 1.31). Where a non-EU person places products itself, the first EU-established person making them available is also deemed an operator (Article 7; Guidance, section 2(a)); a non-EU importer needs an EU or XI EORI number (FAQ 3.7).

Online sales keep the same roles: business-to-business and business-to-consumer supplies are covered, consumer-to-consumer sales are not (FAQ 3.17), a pure intermediary marketplace has no obligation (FAQ 3.18), and a consumer declared as importer is never an operator (FAQ 3.19).

Do You Need a Consultant, Software or Certification to Determine Your Role?

No: the EUDR requires none of them, the EUDR Information System is free (Implementing Regulation (EU) 2024/3084, Article 18(1)), and the operator stays responsible (Article 4(3) and 6(1)). No authority approves EUDR software or providers. No EUDR certificate exists: the output is a reference number or declaration identifier, and certification is information under Article 10(2)(n) (FAQ 5.7). What each scheme proves is set out under certification and the EUDR.

Every rule on this page is checked against EUR-Lex and Commission sources; see our methodology and fact-checking.

This guide explains the rules; it is not legal advice for an individual case.

How Do EUDR Roles Connect to Compliance, the Information System and Enforcement?

The role decides which part of EUDR compliance applies: full due diligence for operators, Article 5 duties for downstream operators and traders. The process for each role runs step by step under EUDR compliance.

How Do Roles Appear in the EUDR Information System?

Operators, micro or small primary operators, non-SME downstream operators and non-SME traders use the EUDR Information System (Articles 4(2), 4a and 5(2)). Access and filing are explained under roles in the EUDR Information System.

Which Roles Does EUDR Enforcement Check?

Authorities check at least 1 %, 3 % or 9 % of operators, non-SME downstream operators and non-SME traders a year (Article 16(8) to (10)), counted per commodity (Article 16(11)). Checks and penalties are covered under EUDR enforcement.

Do EUDR Roles Follow the Old EUTR Operator and Trader Split?

The EUTR also used operators and traders; the EUDR repeals it from 30 December 2026 (Article 37) and adds the downstream operator. The transition to 2029 is explained under EU Timber Regulation (EUTR).

What Do Operators and Traders Most Often Ask About EUDR Roles?

Operators and traders most often ask about renting and downstream geolocation. More of the questions operators, traders and suppliers ask are answered on the FAQ page.

Is Renting Out a Product Making It Available Under the EUDR?

No: in the Commission's view, renting out a relevant product is not making it available on the market (FAQ 2.15). Making available requires a supply for distribution, consumption or use on the Union market in the course of a commercial activity (Article 2(18)).

Do Downstream Operators Have to Collect Geolocation?

No: downstream operators are not required to collect geolocation, in the Commission's view (FAQ 1.1). The geolocation of the plots of land belongs to the operator's due diligence and its DDS, while the downstream operator collects the Article 5(3) supplier and customer information.