Not in the usual case. Under the EU Deforestation Regulation (EUDR), a retailer that buys covered products from another EU business is a trader, with no due diligence and no statement. It keeps supplier and business-customer records, plus reference numbers when it buys straight from the operator. A retailer that imports the goods itself is the operator.
What does a retailer keep?
- The name, postal address and email of each supplier and each business customer, with any trade name and website. Sales to consumers need no customer record.
- The statement reference numbers or declaration identifiers, but only when the supplier is the operator that filed them. Further down the chain, nobody keeps them.
- These records for at least five years, ready for the authorities on request.
The Commission describes this duty as passive. A retailer that receives no reference numbers can presume, in good faith, that its supplier is not the operator.
When does a retailer need to do more?
A large retailer, one above the EU’s SME limits, has to register in the EU information system before selling covered products. Any downstream operator or trader that learns of new information pointing to a problem must tell the authorities and its business customers. A large one with a substantiated concern must also check that due diligence was done and the risk was negligible.
Example: a furniture retailer with three product lines
Example. A large retailer in Sweden sells wooden furniture. Line one comes from the EU importer that filed the statement, so the retailer keeps the reference numbers and supplier details. Line two comes from an EU wholesaler, so it keeps supplier details only. Line three it imports from India itself, so for that line it is the operator and files the due diligence statement.
What changed in December 2025?
Before the amendment that took effect on 26 December 2025, large traders would have been treated as operators and had to do full due diligence; those duties never started. Since then no trader or downstream operator files a statement, and only the first business after the operator keeps reference numbers. The operator and trader answer sets out the roles. Their place in the system is listed for the regulation’s general review, due by 30 June 2030.
Where this comes from: Regulation (EU) 2023/1115, Article 5, as replaced by Regulation (EU) 2025/2650, Article 1(6) and recitals 5 and 6; Commission guidance, OJ C/2026/3896, section 4; Commission simplification review, COM(2026) 191, section 4.1.1.
More on this: EUDR guide · EUDR compliance
Reviewed by Team GreenSutra on 26 October 2026.