If you import into the EU, produce, process or trade within the EU, or export from the EU any of the products covered by the EUDR, you may have responsibilities under the Regulation. This webpage will help you identify your role/s in the supply chain and your responsibilities under the EUDR, using simple examples.
Please use this page in conjunction with the official Guidance, the published FAQs, and the Supply Chain Infographics report which illustrates the obligations of different supply chain roles using various product scenarios. These resources should all be read alongside the EUDR legal text.
What is my role in the supply chain?
You can use this illustrated supply chain example to help identify the role that best matches your activities, then learn more in the role descriptions below. Some companies may have more than one role.
Although this example shows a cattle supply chain, the general activities and roles are relevant across the EUDR commodities. For more detailed examples across different products, see the Supply Chain Infographics report.
Upstream in the supply chain
Operators (also referred to as upstream operators) are those who place a relevant product from EUDR Annex I on the EU market or export it from the EU, in the course of a commercial activity.
- Placing on the market means making a product available on the EU market for the first time. This can apply to products that are produced in the EU or that are imported.
- For the first time does not include situations where a new relevant product is made from other relevant products that were already placed on the EU market and already underwent due diligence. In those cases, the supply chain actor placing the new relevant product on the market is a downstream operator, not an upstream operator.
More information on upstream operators can be found in the Guidance and FAQs, including Guidance sections 2 and 4 and FAQs 1.23, 3.1, 3.5, 5.1 and 5.6.1.
Operators are responsible for carrying out due diligence before placing any relevant product onto the EU market or before directly exporting a relevant product from the EU. This is to ensure the relevant product complies with EUDR requirements.
Once due diligence is complete and the operator has ensured that any risk of non-compliance is negligible, they must submit a due diligence statement with key product information to the EUDR’s online Information System. Once the due diligence statement has been accepted in the System, the operator may place the product on the market or export it. Operators must pass on their due diligence statement number (generated by the Information System) to their direct downstream buyers (known as the first downstream operator or trader), for traceability.
To learn more about due diligence see the Understand due diligence webpage
Upstream micro or small primary operator
A micro or small primary operator is an upstream operator that is:
- a natural person or a micro or small undertaking (defined in the Accounting Directive 2013/34/EU)
- based in a low-risk country (see the EUDR country risk categorisations)
- directly placing relevant products onto the EU market, or exporting them from the EU
- the primary producer of these products, meaning that they have grown, harvested, obtained or raised the product in the country where they are based.
Companies, or the parts of a business related to relevant commodities and products, may fluctuate in size over the years. See section 3 of the FAQs to learn more about qualifying as an upstream micro or small primary operator.
Like other upstream operators, micro or small primary operators are responsible for carrying out due diligence on the relevant products that they place on the EU market or export.
Upstream micro or small primary operators have simplified reporting obligations. Instead of submitting separate due diligence statements, they can submit a one-off simplified declaration to the Information System.
Simplified declarations:
- contain key information on the relevant products that the upstream micro or small primary operator plans to place on the EU market
- are less detailed than due diligence statements
- only need to be updated if there are any important changes to the information
- can contain the postal address of the establishment or of the plots of land where the products are produced, instead of geolocation coordinates or point/polygon data
- can be submitted by Member State authorities on behalf of the upstream micro or small primary operator, if the authorities have all the necessary information.
Upstream micro or small primary operators must pass on their simplified declaration identifier (generated by the Information System) to their direct downstream buyers (known as the first downstream operator or trader), for traceability.
More information on upstream micro or small primary operators can be found in the Guidance and FAQs, including Guidance sections 2 and 4 and FAQs 1.23, 3.1, 3.21-3.30 and 5.6.1.
To learn more about due diligence see the Understand due diligence webpage
An authorised representative is an EU‑based natural person or company that an upstream operator formally appoints to submit due diligence statements or simplified declarations to the Information System on their behalf. Authorised representatives must register separately from operators in the Information System, and they must provide Competent Authorities with a copy of their written mandate from the operator upon request.
All upstream operators, including micro or small primary operators, can choose whether or not to appoint an authorised representative. However, the upstream operator is still fully responsible for ensuring that their relevant products comply with the EUDR.
Any natural or legal person (whether private or public) established in the EU can act as an authorised representative. They may be independent service providers or, in some cases, downstream actors in the operator’s supply chain. An upstream operator that is a natural person or microenterprise can mandate the next downstream operator or trader in their supply chain (as long as they are not also a natural person or microenterprise) to act as their authorised representative. Company groups can choose to mandate one of their members as an authorised representative to submit due diligence statements on behalf of all group members. In the case of forest owners and farmers, associations such as forest associations can act as an authorised representative.
More information on authorised representatives can be found in the FAQs, including FAQs 5.2, 5.2.1, 3.13 and 3.15.
What if I am based outside of the EU but I am placing on the EU market?
The upstream operator is generally the person (including companies) who imports relevant products into the EU under the customs procedure ‘release for free circulation’. To do this, they must have a valid EU EORI number and be registered in the Information System. If the person or company doing this is established in a non-EU country, then they are still acting as an upstream operator.
In this type of supply chain, the first EU-based company or natural person that sells those products on the EU market (makes them available) is also considered to be an operator. This means that the same supply chain can have both:
- an upstream operator established outside the EU, and
- an upstream operator established within the EU.
This is because there must always be at least one upstream operator in the supply chain who is established in the EU. Both operators must conduct due diligence for the relevant products and each submit their own due diligence statement (or simplified declaration for micro or small primary operators) to the Information System.
More information on operators established outside the EU can be found in the Guidance and FAQs, including Guidance section 2 and FAQ 3.7.
Does the EUDR apply to smallholders in third countries?
The Regulation only applies to you if you place relevant products onto the EU market yourself. Selling relevant products to a cooperative or company in your own country, in another non-EU country, or to an EU-based buyer who will import those products into the EU does not count as placing directly on the EU market.
However, smallholders that are not themselves placing on the EU market may still be asked by buyers for information such as the geolocation of the plots of land where they produce, harvest or raise relevant products.
Downstream in the supply chain
Downstream supply chain actors are companies or natural persons that sell relevant products within the EU, or export them from the EU, after those products or their EUDR-relevant parts have already undergone due diligence upstream. This includes situations where new relevant products (with a different Combined Nomenclature / Harmonised System product code) are made using products that were already subject to upstream due diligence.
Downstream actors are either downstream operators or traders, based on their activities.
Downstream operators are supply chain actors who, in the course of a commercial activity:
- place on the market or export relevant products and
- all of those relevant products have already undergone upstream due diligence.
Downstream operators are usually those who process such products into other relevant products (causing a change in the EUDR Annex I CN/HS product code) and then place them on the EU market or export them. For example, a company in the EU making chocolate from cocoa beans would be a downstream operator when selling or exporting the chocolate, as long as all of the cocoa beans had already been placed on the EU market by an upstream operator.
Traders are downstream supply chain actors who usually:
- sell relevant products already subject to upstream due diligence within the EU,
- without changing the Annex I CN/HS product code.
More information on downstream operators and traders can be found in the Guidance and FAQs, including Guidance section 2 and FAQs 3.1, 3.1.1, 3.4 and 5.6.1.
How does company size affect downstream obligations?
All downstream operators and traders are responsible for:
- collecting and keeping certain information on their suppliers and their buyers for at least 5 years and showing this information to Competent Authorities on request, and
- notifying buyers and relevant Competent Authorities if they find out that a product might not comply with the EUDR.
They do not need to carry out due diligence, submit due diligence statements or simplified declarations, or have a due diligence system in place.
Large downstream operators and traders must also:
- register in the Information System, although they do not need to submit anything to the System after registering, and
- verify upstream due diligence was carried out and found only negligible risk, but only if they find out that a product might not comply with the EUDR.
Micro, small or medium-sized enterprise (SME) downstream operators and traders (defined in Article 3 of Accounting Directive 2013/34/EU) do not have to register in the Information System or verify upstream due diligence.
More information on company size can be found in the FAQs, including FAQs 3.1, 3.4, 3.6.2 and 3.10.
To learn more about verifying upstream due diligence, see the Understand due diligence webpage
First downstream operator or trader
The first downstream operator or trader is the supply chain actor that is the first buyer of a relevant product from an upstream operator or micro or small primary operator.
As well as the general responsibilities of downstream operators and traders, the first downstream operator or trader must also:
- collect the due diligence statement (DDS) reference number or simplified declaration identifier for the relevant product from the upstream operator or micro or small primary operator
- keep a record of DDS reference numbers or simplified declaration identifiers for at least 5 years
- but does not need to pass DDS numbers or declaration identifiers on to their own buyers.
How do I know if I am the first downstream operator or trader?
If your supplier passes on a DDS reference number or simplified declaration identifier to you then you can assume that they are the upstream operator/micro or small primary operator and that you are the first downstream operator/trader.
- it is the obligation of the upstream operator/ micro or small primary operator to pass on their reference number/identifier if you are their first downstream buyer
- you do not need to self-identify
- you do not need to ask your supplier for numbers/identifiers
More information on the first downstream can be found in the FAQs, including FAQs 1.23, 3.1, 3.4, 3.5, 3.6.1 and 3.8.
Do consumers have EUDR responsibilities?
Consumers — for example, people buying products from a shop or retailer — are at the end of the supply chain and do not have responsibilities under the EUDR. The Regulation does not place any requirements on non‑commercial consumers, as private use and consumption are outside the scope of the EUDR.
Who is liable if the EUDR is breached?
Upstream operators (including micro or small primary operators) are responsible for the compliance of the relevant products they place on the EU market or export. However, upstream operators (including micro or small primary operators), downstream operators and traders must all comply with the obligations applicable to them under the EUDR
What is the role of EU Member States’ Competent Authorities?
EU Member States’ Competent Authorities (CAs) are national bodies that support harmonised implementation and enforcement of the EUDR across the EU-27. They work with other authorities including customs authorities.
CAs conduct checks on upstream operators (including micro or small primary operators), downstream operators and traders to ensure that they are compliant with their obligations and that relevant products that have been, or are intended to be, placed on, made available on, or exported from the EU market are compliant with the EUDR. Checks may include verifying the validity of due diligence statements and simplified declarations, checking due diligence systems and records, and conducting site or field audits. CAs can also issue penalties, including fines.
CAs also support upstream operators, downstream operators and traders to comply with the EUDR by providing information materials on their national websites (often in national languages) and running training sessions that are specific to the national context of their Member State.
More information on CAs can be found in the FAQs, including FAQs 1.20-1.22.
Timelines: when does the EUDR start to apply to me?
The EUDR enters into application (that is, starts to apply) for large and medium enterprises on 30 December 2026 and for most micro and small enterprises on 30 June 2027. For micro and small enterprises already covered by the EU Timber Regulation (EUTR), entry into application is 30 December 2026.
How have the 2025 amendments changed my responsibilities?
The EUDR was amended in December 2025 to simplify and streamline obligations and reduce the data load on the Information System. Compare the roles and responsibilities of supply chain actors before and after the 2025 amendments in the infographic below:
For more information on how the EUDR applies to you
Read the Supply Chain Infographics, the FAQs and the Guidance, or contact your Member State Competent Authority.