An operator under the EU Deforestation Regulation (EUDR) is the business that places a product on the EU market for the first time, or exports it. A trader sells it on further down the chain. A third role, the downstream operator, covers businesses that make products from inputs already covered. Only operators carry out due diligence and file statements.
How are the three roles defined?
| Role | Who it is | Due diligence and statement? |
|---|---|---|
| Operator | Places the product on the EU market for the first time, or exports it | Yes |
| Downstream operator | Places on the market or exports a product made from inputs that are all covered by a statement or a simplified declaration | No |
| Trader | Anyone else in the chain who sells the product on in the EU | No |
Only the first downstream operator or trader after the operator keeps the statement reference numbers; businesses further down keep none. The answer on EU retailers sets out exactly what they hold.
Example: cocoa beans to chocolate
Example. An importer brings cocoa beans into the EU and files the statement, so it is the operator. A chocolate manufacturer that buys those beans inside the EU and turns them into bars is a downstream operator, the case the Commission’s guidance uses. A wholesaler that resells the bars is a trader.
Can one business hold more than one role?
Yes. Roles are judged product by product. A company that imports beans and then makes chocolate from them is an operator for the beans and a downstream operator for the bars.
What changed in December 2025?
The amendment that took effect on 26 December 2025 created the downstream operator role. Before it, large traders would have been treated as operators and filed statements of their own; those duties never started, because the dates kept moving. Since that date neither downstream operators nor traders file. The roles of downstream operators and traders are listed for the regulation’s general review, due by 30 June 2030.
Where this comes from: Regulation (EU) 2023/1115, Article 2, as amended by Regulation (EU) 2025/2650, Article 1 and recital 5; Commission guidance, OJ C/2026/3896, section 2.
More on this: EUDR guide · EUDR compliance
Reviewed by Team GreenSutra on 26 October 2026.