EUDR Operator vs Trader: Which Are You?

The EUDR doesn't treat everyone in the supply chain the same way. It assigns two distinct roles (operator and trader) and the obligations attached to each are very different. Getting your classification wrong can leave you either over-engineering your compliance process or, worse, exposed to fines you didn't see coming.

This is the question most SME importers should ask first, before anything else.

The two roles EUDR defines and why they matter

Article 2(15) of Regulation (EU) 2023/1115 defines an operator as any person who, in the course of a commercial activity, places relevant products on the EU market or exports them.

Article 2(16) defines a trader as any person in the supply chain, other than an operator, who makes relevant products available on the EU market.

The word "places" in Article 2(15) is doing a lot of work here. It refers to the first time a product enters the EU market. Whoever does that is the operator — and they carry the heaviest compliance burden. Traders come after that first placement, moving goods within the EU.

What makes you an operator (plain language)

You are an operator if you are the first entity to bring a regulated commodity into the EU from outside it.

In practice: if you import green coffee from Brazil and you are the importer of record, you are the operator. It doesn't matter whether you roast the coffee yourself or sell it on to another business. The act of placing it on the EU market makes you the operator.

There's a scenario that trips up a lot of SMEs. Say you buy roasted coffee from a Dutch trading company that imported it from Brazil. You might assume the Dutch company is responsible and you're just a downstream buyer. But if that Dutch company is a registered EU business that imported the coffee and submitted a Due Diligence Statement when it first arrived, then they are the operator, not you.

However, if you are the one importing directly from a non-EU country under your own import declaration, you are the operator regardless of what any intermediary tells you.

What makes you a trader (and the SME carve-out)

You are a trader if you are buying and reselling regulated products that have already been placed on the EU market by someone else. You didn't do the importing — you're moving goods that are already inside the EU.

Traders face lower obligations than operators, but they're not off the hook. They must be able to produce the Due Diligence Statement reference number from the original operator when asked by authorities.

The regulation includes a carve-out worth knowing about. Under Article 4(8), micro and small enterprises acting as traders (those with fewer than 50 employees and annual turnover under EUR 10 million) can rely on the operator's DDS reference number rather than conducting their own full due diligence. You pass the reference number downstream and you're done.

This is genuinely useful for small distributors and resellers. It's not a free pass: you still need that reference number, and you still need to store it. But it's significantly lighter work than running your own satellite risk assessment.

Your obligations as an operator: full due diligence

If you're an operator, you must complete the full due diligence system (DDS) before placing goods on the market. There are no shortcuts.

You collect geolocation data (GPS coordinates or polygon data) for every plot of land where your commodity was produced. You then conduct a risk assessment using satellite imagery and other verifiable evidence to confirm no deforestation occurred after December 31, 2020. Once that's done, you submit a Due Diligence Statement through the EU TRACES NT system and receive a reference number before your goods clear customs.

You also need to document your methodology and keep records for at least five years. If a competent authority asks to audit your DDS, you need to be able to show your work. For more on what the DDS requires in practice, see our guide to EUDR due diligence statement requirements.

Fines hit operators first and hardest: up to 4% of EU-wide annual turnover for serious violations, plus potential confiscation of goods. The regulatory risk sits with whoever placed the product on the market.

Your obligations as a trader: simplified declaration or full DDS

If you're a trader and you qualify as micro or small under the SME definition, your main obligation is to obtain and store the operator's DDS reference number. You pass it on when asked. You don't run your own geolocation collection or satellite checks.

If you're a larger trader (more than 50 employees or over EUR 10 million in annual turnover), you don't get the simplified route. You must conduct your own due diligence, the same as an operator would, even though you didn't do the original import. That's a significant obligation that many mid-sized distributors aren't aware of.

In either case, traders can't simply say "my supplier is responsible." You need documented evidence that the goods were properly covered by a DDS when they entered the EU.

The grey zone: importers who source through intermediaries

This is the scenario that most EUDR explainers skip, and it's probably the one that applies to many readers here.

You source your commodity (cocoa, coffee, soy) through a European trading company or broker. You never touch the original exporting country. The goods arrive in your warehouse already inside the EU, sold to you by a Dutch, German, or Belgian intermediary.

Are you the operator or the trader?

The answer depends on whether your intermediary already submitted a DDS when they first imported the goods. If they did, and they can give you their reference number, you're a trader, and if you're small enough, the simplified route applies to you.

But here's where it gets complicated. Some intermediaries source from non-EU countries and pass goods to you without having completed EUDR compliance themselves. They may claim the goods are compliant without being able to produce a DDS reference number. In that case, you could find yourself with uncovered goods and no upstream DDS to point to.

The practical rule: before you close any supply contract, ask your EU-based supplier for their DDS reference number or their TRACES NT registration. If they can't provide it, one of you will need to go back to the source, and it may end up being you.

Don't assume someone upstream already handled it. The regulation doesn't allow that assumption, and customs authorities won't accept it either.

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If you're still not sure where you fall, you're not alone. The operator/trader line is clear in the regulation's text but blurry in real supply chains with multiple intermediaries, mixed sourcing, and contracts written before EUDR existed.

TracePlot asks you a short series of questions during onboarding to determine your role, identify which of your sourcing relationships carry operator-level risk, and build a compliance workflow that matches your actual situation. Read about how to comply with EUDR in 2026 for a step-by-step overview of the full process.