The EUDR does not oblige every company in the chain in the same way. Whoever imports coffee, cocoa or wood has to submit a due diligence statement before each shipment; whoever buys afterwards from an EU importer only has to collect and keep data. Knowing which role you play, operator, downstream operator, trader or micro or small primary operator, is the first step to knowing what applies to you and from when.
Short answer
- The operator is whoever places the product on the EU market or exports it: it exercises due diligence and submits the statement (DDS) before each operation (Arts. 2(15) and 4).
- The downstream operator and the trader do not submit a DDS: they collect and keep data of suppliers and customers and the reference numbers (Art. 5). If they are not SMEs, they register in the information system.
- The micro or small primary operator submits a one-time simplified declaration (Art. 4a).
- Application: 30 December 2026 for large and medium-sized companies, and downstream operators and traders; 30 June 2027 for micro and small operators established as such on 31 December 2024, with exceptions.
Which products the EUDR covers
Regulation (EU) 2023/1115 applies to seven commodities, cattle, cocoa, coffee, oil palm, rubber, soy and wood, and to the Annex I products that contain them or are made with them (Art. 1). For example, it covers coffee beans (0901), cocoa beans, butter and powder, and chocolate (1806). From 30 December 2027 instant coffee, palm derivatives and frozen beef tongue are added (Delegated Regulation (EU) 2026/2102).
Which role are you? A four-question tree
Answer in order and stop at the first answer that fits.
Do you produce what you sell or export yourself, are you a natural person or a micro or small enterprise, and are you in a low-risk country?
Yes: you are a micro or small primary operator: one-time simplified declaration (Art. 4a).
No: go to question 2.
Do you place the product on the EU market for the first time or export it from the EU? If the producer is outside the EU, are you the first person in the EU to place it on the market (Art. 7)?
Yes: you are an operator: due diligence and DDS before each operation.
No: go to question 3.
Do you make another Annex I product from products already covered by a DDS and place it on the market or export it?
Yes: you are a downstream operator: you do not submit a DDS, you keep data and reference numbers.
No: go to question 4.
Do you resell Annex I products without processing them?
Yes: you are a trader: the same obligations as the downstream operator.
No: if you are outside the EU and sell to an importer, your importer is the operator and you give them the data; if your product is not in Annex I, the EUDR does not apply to you today.
The same company may have several roles at once, depending on the product. And an operator may appoint an authorised representative to submit the DDS on its behalf, while remaining responsible (Art. 6).
The four roles in the chain
| Role | Who it is (Art. 2) | What it has to do | Submits a DDS? |
|---|---|---|---|
| Operator | Places the products on the EU market or exports them, except downstream operators | Due diligence (Art. 8); DDS before each operation; record for 5 years (Art. 4) | Yes |
| Downstream operator | Places on the market or exports products made with products already covered by a DDS or a simplified declaration | Collect and keep supplier, customer and reference-number data; register if not an SME (Art. 5) | No |
| Trader | Makes products available without being an operator or downstream operator | The same as the downstream operator (Art. 5) | No |
| Micro or small primary operator | Natural person or micro or small enterprise from a low-risk country that sells or exports what it has produced itself | One-time simplified declaration, with identifier (Art. 4a) | Simplified |
Seven common cases
| Your situation | Role | What applies to you |
|---|---|---|
| You import green coffee or cocoa beans from outside the EU and clear them for free circulation | Operator | DDS per operation, due diligence, EORI |
| You export Annex I products from the EU | Operator (exports) | DDS before exporting |
| You import green coffee, roast it and sell it | Operator for the imported coffee | The DDS covers the green coffee you import; selling the roasted coffee afterwards in the EU does not require another DDS |
| You buy cocoa already covered by a DDS and make chocolate under your brand | Downstream operator | You do not submit a DDS: you keep data and references; register if you are not an SME |
| You buy from an EU importer and resell without processing | Trader | You keep supplier and customer data and the reference number; register if you are not an SME |
| You are a producer or cooperative outside the EU and sell to an importer | Not an operator | Your importer will ask you for the origin and plot geolocation (Art. 9) |
| You yourself produce wood, cattle or soy in a low-risk country and are a natural person or a micro or small enterprise | Micro or small primary operator | One-time simplified declaration |
The same company may have several roles at once, depending on the product. A chocolate maker that imports cocoa directly is an operator for that cocoa and, for the cocoa it buys already declared, a downstream operator.
From when it applies
| Who | Application |
|---|---|
| Large and medium-sized companies | 30 December 2026 (Art. 38(2)) |
| Operators that are natural persons, micro-enterprises or small enterprises, established as such on 31 December 2024 (except EUTR wood products) | 30 June 2027 (Art. 38(3)) |
| Downstream operators and traders, including micro and small ones (Art. 38(3) only mentions operators) | 30 December 2026 |
| New Annex I products (instant coffee, palm derivatives and frozen beef tongue) | 30 December 2027 (Delegated Regulation (EU) 2026/2102) |
Products placed on the market before 30 December 2026 do not need a DDS (Commission FAQ 8.2 and 9.2). The simplification review that the Commission published on 4 May 2026 did not amend the base text of the Regulation.
What your European customer will ask you for
Even if you are not an operator, your European customer is one or depends on one. That is why it usually asks you for: country and plots of origin with their geolocation (six decimals, polygon for plots over 4 ha), evidence that the product complies with the legislation of the country of production and batch traceability. The Commission does not accept mass balance: a batch mixed with a deforested plot is non-compliant (FAQ 1.4 and 1.5). The guide on the due diligence statement details what data it contains.
How to know what applies to you
- Review your products and their Harmonised System code against Annex I.
- Identify your role per product: do you place it on the EU market yourself, or do you buy from someone who already did?
- Ask your suppliers for origin, plots and reference numbers, depending on your role.
- Check your date: 30 December 2026 or 30 June 2027, depending on your size.
What Retexcycle can do for your role
| Your role | What you need | With Retexcycle |
|---|---|---|
| Operator (EU importer or exporter) | Gather supplier information, assess risk and submit the DDS in TRACES NT | Compliance Hub: suppliers, country risk assessment, DDS generation and sending to TRACES NT |
| Downstream operator or trader | Keep supplier and customer data and the reference numbers | Compliance Hub: register of references and customers, with auditable files |
| Producer, cooperative or exporter from outside the EU | Give your importer origin, geolocation and evidence per batch | Origins: plot capture at origin and verified traceability for your customer |
The DDS guide explains each field of Annex II.
Retexcycle Compliance Hub · Origins
Are you an operator, downstream operator or trader?
Tell us your case and we will help you identify what applies to you and what data to ask your suppliers for before the application dates.
Frequently asked questions: who has to comply with the EUDR
Who has to comply with the EUDR?
Any company that places on the EU market, makes available or exports Annex I products (coffee, cocoa, rubber, palm, soy, wood, cattle and their derivatives). Depending on its position in the chain it will be an operator, downstream operator, trader or micro or small primary operator, and the obligations differ for each.
What is an operator under the EUDR?
Any natural or legal person who, in the course of a commercial activity, places the relevant products on the EU market or exports them, excluding downstream operators (Art. 2(15)). The importer that clears green coffee for free circulation is one example.
What is the difference between a downstream operator and a trader?
The downstream operator places on the market or exports products made with relevant products already covered by a DDS, such as the chocolate maker that buys already-declared cocoa. The trader only makes products available, without being an operator or downstream operator. Neither submits a DDS (Art. 2 and Art. 5).
If I buy from an EU importer, do I have to submit a DDS?
No, if you are not the one placing the product on the market. As a downstream operator or trader you collect and keep the data of your supplier and your customers, including the DDS reference number, and if you are not an SME you register in the information system (Art. 5).
Does a producer or exporter outside the EU have obligations?
As an operator, no, as long as it is not the one placing the product on the EU market (Commission FAQ 3.21). It will have to give its importer the origin data and plot geolocation, because the importer needs them for its DDS (Art. 9).
What is an SME for the purposes of the EUDR?
The micro, small and medium-sized enterprise thresholds of Directive 2013/34/EU apply (Art. 2(30)). The status of micro or small primary operator also requires being a natural person or a micro or small enterprise, being established in a low-risk country and selling what you have produced yourself.
What happens if I do not comply with the EUDR?
Penalties must be effective and dissuasive: fines with a maximum of at least 4% of annual EU turnover, confiscation of the product and of the revenue, and temporary exclusion from public procurement for up to 12 months (Art. 25).
Verified against the consolidated text of Regulation (EU) 2023/1115 (18/09/2026) and the Commission's FAQ (v5, April 2026), in October 2026. Informational summary, not legal advice. Sources: Regulation (EU) 2023/1115; Regulation (EU) 2025/2650; Delegated Regulation (EU) 2026/2102.
