Only indirectly, unless it acts as importer itself. Under the EU Deforestation Regulation (EUDR), the business that first places the goods on the EU market, usually the importer, carries out due diligence and files the statement. The non-EU exporter supplies the information that work depends on, above all the location of every plot that produced the goods.
Who is the operator when goods come from outside the EU?
In most cases it is whoever acts as importer when the goods are released for free circulation, the person named in that field of the customs declaration. A sale agreed outside the EU is not yet placing the goods on the market. If the importer of record is itself a business outside the EU, it becomes an operator. The first business established in the EU that sells the goods on is then treated as an operator as well. A consumer named as importer never is one. Freight forwarders and customs agents that never own the goods are neither operators nor traders.
What reaches the exporter anyway?
For each product the operator has to hold the supplier’s name, postal address and email. It also holds the geolocation of every plot with the date or period of production, and evidence that the goods were produced legally and without deforestation. Most of that can only come from the exporter and its own suppliers, and the operator cannot file its due diligence statement without it.
An exporter that chooses to act as importer can appoint a representative to file for it, but that representative must be established in the EU.
Example: green coffee into Germany
Example. A growers’ cooperative outside the EU sells green coffee to a roaster in Germany, and the roaster lodges the customs declaration as importer. The roaster is the operator. It files the statement and gives customs the reference number before the coffee is released. If the cooperative lodged the declaration itself, it would be an operator, and the roaster would count as one too.
What is still open?
Non-EU operators’ access to the EU information system came up as a concern in the Commission’s simplification review of 4 May 2026. Since 15 October 2026, statements from operators outside the EU are assigned to a Member State through the operator’s identifier. Online and distance sales are dealt with in the Commission’s FAQ rather than in the regulation. The dates from which all this applies are in when EUDR applies by company size.
Where this comes from: Regulation (EU) 2023/1115, Articles 2(16), 7 and 9(1); Regulation (EU) 2025/2650, Article 1; Commission guidance, OJ C/2026/3896, section 2.
More on this: EUDR guide · EUDR compliance
Reviewed by Team GreenSutra on 26 October 2026.