Quick summary: EUDR compliance assigns different obligations to operators, traders, and retailers. Discover your role, your due diligence duties, and the penalties for non-compliance
Under the EU Deforestation Regulation (Regulation (EU) 2023/1115, as amended by (EU) 2025/2650), EUDR roles and responsibilities fall into four groups: operators, traders, downstream operators, and authorised representatives. Your role not your industry decides whether you file a full Due Diligence Statement (DDS) in EU TRACES, reference an upstream one, or simply keep traceability records. Operators placing a commodity on the EU market for the first time carry the heaviest EUDR roles and responsibilities; downstream operators and most SME traders carry lighter, traceability-focused duties
Confirm your role first everything else follows from it.
Your role sets whether you build plot-level geolocation, file a DDS, or pass a reference down the chain.
Guessing wrong means over-building (duplicating upstream work) or under-building (a blocked shipment).
If you source or sell coffee, cocoa, soy, palm oil, rubber, cattle, or wood into the EU, the first question a competent authority, a customs officer, or your EU buyer asks is not “are you compliant?” It is “what role do you play?” Your EUDR roles and responsibilities determine every downstream cost. The regulation itself is knowable in an afternoon; the pain shows up when you map it onto real data. Your ERP stores invoices and supplier addresses not GPS polygons, land-use history, or deforestation cut-off checks. Mapping your EUDR roles and responsibilities onto evidence you can actually produce on demand is where compliance breaks for most teams.
Here are the EUDR roles and responsibilities exactly as the regulation defines them, with the obligation each one triggers.
Any natural or legal person who, in the course of a commercial activity, places relevant commodities or products on the EU market for the first time, or exports them. Operators carry the full weight: collect geolocation for every production plot, run risk assessment and mitigation, and file a Due Diligence Statement in EU TRACES before the goods move. Importers, first-placers, and exporters sit here.
Are You an Upstream Operator Under EUDR?
Our guide breaks down EUDR requirements for upstream operators, helping you understand your role, obligations and the evidence you need to maintain.
Read the complete guide to EUDR for Upstream Operators.
Any person in the supply chain, other than the operator, who makes relevant products available on the market. Non-SME traders are treated like operators and file a full DDS. SME traders may reference an existing upstream DDS by its reference number and retain record but a substantiated concern or a direct import from outside the EU can pull them back into full DDS territory.
Are You a Trader Under EUDR?
Our guide breaks down EUDR requirements for traders, helping you understand your responsibilities and prepare for compliance.
Read the complete guide to EUDR for Traders.
An entity that places on the market or exports products already covered by a DDS filed upstream. Downstream operators skip fresh due diligence, but they must register in the system, collect and retain upstream DDS reference numbers, keep traceability records, and act on red flags. Less paperwork, zero permission to ignore compliance.
What Does EUDR Mean for Downstream Operators?
Our guide breaks down EUDR requirements for downstream operators, including the key responsibilities, data requirements and compliance considerations you need to understand.
Read the complete guide to EUDR for Downstream Operators.
Micro-enterprises and natural persons may mandate the next operator or trader down the chain as an authorised representative. Micro and small primary producers can use a simplified one-time declaration rather than a full DDS per shipment.
Are You a Micro or Small Operator Under EUDR?
If you’re unsure whether your business qualifies or what the rules mean for your operations, this guide is a good place to start.
Read our complete guide to Micro & Small Operators Under EUDR.

Once you know your role, your EUDR roles and responsibilities become a finite checklist instead of an open-ended fear. This is what each actor actually owns:
| Role | Files a DDS? | Plot geolocation duty | Core obligation |
|---|---|---|---|
| Operator | Yes — full | Yes — collect & verify | Due diligence + DDS in EU TRACES before placing on market |
| Non-SME trader | Yes — full | Yes (via suppliers) | Treated as an operator; full due diligence and DDS |
| SME trader | Reference | No — reference upstream | Retain DDS references; act on substantiated concern |
| Downstream operator | Reference | No — verify upstream | Register, retain DDS references, keep traceability, monitor risk |
| Micro/small primary | Simplified | Yes — origin data | One-time simplified declaration; may use a representative |
The amended regulation did not change your EUDR roles and responsibilities it changed when they bite.
EUDR roles and responsibilities are a data-retrieval problem, not a policy problem. Every role operator, trader, downstream operator ultimately has to produce the same underlying evidence on demand: geolocation, DDS references, supplier records, chain of custody. Companies that stay audit-ready run all of it from one data layer, not fifteen spreadsheets and a WhatsApp thread.
TraceX EUDR Solutions helps companies operationalize EUDR roles and responsibilities by mapping each supply-chain actor to the workflows and evidence relevant to their role. For upstream operators, TraceX supports supplier onboarding, plot-level geolocation, legality documentation, deforestation-risk assessment, risk mitigation and DDS preparation. Micro and small primary operators can be managed through simplified data and declaration workflows where applicable. For downstream operators, TraceX helps connect processed products to upstream EUDR evidence, maintain supplier and product traceability, and retain the required records. Traders can use TraceX to capture supplier/customer information, link products to upstream compliance evidence and maintain audit-ready records. For companies acting in multiple roles, TraceX provides a unified view of obligations, suppliers, products, transactions and compliance evidence, helping teams apply the right workflow to each transaction rather than treating the entire supply chain the same way.
Before you sign with any traceability vendor, pressure-test it against your actual EUDR roles and responsibilities:
EUDR roles and responsibilities split into four groups. Operators place a commodity on the EU market first and file a full DDS. Traders resell within the EU non-SMEs file a full DDS, SMEs reference an upstream one. Downstream operators handle products already covered by a DDS and mainly keep records. Authorised representatives act on behalf of micro-enterprises and natural persons.
If you place a relevant commodity or product on the EU market for the first time, or export it, you are an operator (Article 2(15)). If you make products available on the market after that first placement, you are a trader (Article 2(16)). The first-placement test, not your business label, decides.
Non-SME traders must file a full DDS, just like operators. SME traders may reference an existing upstream DDS by its reference number and retain records unless a substantiated concern or a direct non-EU import triggers full obligations.
Regulation (EU) 2025/2650 introduced the downstream operator: an entity placing or exporting products already covered by an upstream DDS. They skip fresh due diligence but must register, retain DDS references, keep traceability records, and monitor for red flags.
Size affects the timeline and some obligations, not your core role. Micro and small operators get to 30 June 2027 (non-timber) and can use simplified declarations, but they are still in scope not exempt.
Both directions cost you. Over-classifying wastes budget duplicating upstream due diligence; under-classifying risks a missing DDS, a rejected shipment, and fines of up to 4% of EU-wide turnover. Confirming your role first is the cheapest insurance.
For large and medium operators and traders, 30 December 2026. For natural persons and micro/small non-timber operators, 30 June 2027. The 31 December 2020 deforestation cut-off applies regardless of role or size.