Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
The distinction between operator and trader determines what you actually have to do under the EU Deforestation Regulation.
And following the EUDR changes adopted in December 2025, older explanations of operator and trader obligations may no longer be accurate.
Operator vs downstream operator vs trader at a glance
Role | What you do |
|---|---|
Operator | Place a relevant product on the EU market for the first time or export it |
Downstream operator | Place or export a relevant product already covered upstream, including certain products made from relevant products |
Trader | Make a relevant product available on the EU market without being the operator or downstream operator |
The classification applies to the specific relevant product, not simply to the company as a whole.
A business can therefore occupy different EUDR roles for different transactions.
or both?
Not sure which EUDR role applies to your products? The EUDR checker shows whether the regulation applies to your business and what it asks of you.
An operator is a natural or legal person who, in the course of commercial activity, places relevant products on the market or exports them.
The easiest way to understand this is to look for the point where a relevant product first enters the EU market.
Example: importing coffee
A German company imports covered coffee directly from Brazil and places it on the EU market.
The German importer is generally the operator.
Example: EU-grown timber
An EU forestry business harvests relevant timber and places it on the EU market.
That business may be the operator.
Example: exporting a relevant product
For exports, the operator is generally the person acting as exporter when the relevant product is declared under the customs export procedure.
What is an EUDR operator?
What is a downstream operator?
Under Article 2(15b), as amended by Regulation (EU) 2025/2650, a downstream operator is any person who, in the course of a commercial activity, places on the market or exports relevant products made from relevant products that were already placed on the market.
Consider a chocolate manufacturer.
It buys covered cocoa beans already placed on the EU market, manufactures covered chocolate and then places that chocolate on the EU market.
The Commission’s 2026 guidance uses essentially this type of scenario to illustrate a downstream operator.
This category matters because the revised EUDR simplified obligations further down the supply chain.
What is an EUDR trader?
A trader is a person in the supply chain, other than an operator or downstream operator, who makes relevant products available on the market in the course of commercial activity.
In simple terms, a trader typically distributes or resells an already-covered relevant product without being the actor that first placed it on the market or creating another relevant product in circumstances that make it a downstream operator.
Importer, manufacturer or retailer: which are you?
Your normal business label does not decide your EUDR status.
Importer
If you import a relevant product from outside the EU and place it on the EU market for the first time, you will generally be an operator.
Manufacturer
If you use an already-covered relevant product to manufacture another product listed in Annex I and place that new relevant product on the market, you may be a downstream operator.
Distributor
If you simply distribute an already-placed relevant product without transforming it into another relevant product, you may be a trader.
Retailer
A retailer selling covered products already placed on the EU market may be a trader, depending on the product and transaction.
Exporter
A company exporting a relevant product may be an operator or downstream operator depending on whether that product was already covered upstream.
Can the same company be both operator and trader?
Yes.
This is one of the most important points in the Commission’s 2026 guidance.
EUDR status is assessed for each relevant product.
A company could therefore be:
- an operator for imported coffee;
- a downstream operator for a manufactured relevant product; and
- a trader for another relevant product it simply resells.
That is why assigning one permanent EUDR label to an entire company can produce the wrong compliance workflow.
per product
Operator for one product, trader for another? EUDR Passport records your role in each product profile and files the due diligence statement where one is required. Or book a walkthrough.
Who performs EUDR due diligence after the 2025 changes?
This is where many older EUDR articles are now misleading.
The revised framework concentrates the main due diligence responsibility on the operator first placing a relevant product on the EU market or exporting it.
The Commission explains that downstream operators and traders are no longer generally required to submit their own due diligence statements or independently ascertain that due diligence was exercised throughout the supply chain.
Instead, under Articles 5 and 7 they must collect and keep the reference numbers of the due diligence statements or simplified declarations where their supplier is an operator, and keep records; those that are not SMEs must also register in the Information System. Only operators pass reference numbers on (Article 4(7)).
That makes correctly identifying the first operator much more important.
A simple EUDR role test
Ask these questions for each relevant product:
1. Is the product covered by Annex I of the EUDR?
If no, EUDR does not apply to that product.
If yes, continue.
2. Are you first placing that product on the EU market or exporting it without it already being covered upstream?
You are likely the operator.
3. Are you placing/exporting a relevant product that has already been covered upstream, including a new relevant product made from covered inputs?
You may be a downstream operator.
4. Are you simply making an already-covered relevant product available on the EU market?
You may be a trader.
Operator vs downstream operator vs trader
Getting your role wrong can mean getting your compliance obligations wrong.
An operator may need a complete workflow covering:
supplier information → geolocation → risk assessment → mitigation → due diligence statement/reference information
A downstream operator or trader may have a substantially different workflow under the revised EUDR.
Compliance software should therefore determine obligations based on the transaction and supply-chain position rather than treating every supplier, customer and product identically.
Frequently asked questions
Generally, yes, when it is the person first placing a relevant product imported from outside the EU onto the EU market.
A retailer selling relevant products already placed on the EU market may be a trader, but classification depends on what it does with the specific product.
Depending on the transaction, a manufacturer can be an operator or downstream operator. The product, its prior status and whether another relevant product is created all matter.
Yes. The Commission expressly states that a company may hold multiple roles simultaneously for different relevant products.
Under the revised EUDR framework, downstream operators and traders are no longer generally required to submit their own DDS simply because they handle a relevant product. Specific traceability, registration and information obligations may still apply.
The bottom line
The question is no longer simply:
“Is my company an operator or a trader?”
The better question is:
“What is our role for this particular product and transaction?”
That answer determines which EUDR obligations follow. EUDR Passport records the role per product profile and files the due diligence statement where one is required.
External sources: European Commission 2026 EUDR Guidance; consolidated Regulation (EU) 2023/1115.
Related reading: which products fall within EUDR scope, what a single plot must contain under the geolocation requirements, and the 30 June 2027 deadline for small businesses.
Need software for EUDR due diligence? EUDR Passport is free to set up, free for your suppliers, and costs €90 per product profile per year with unlimited DDS.
30 DECEMBER 2026
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