EUDR Due Diligence Obligations: Practical Examples by Company Role

The EUDR due diligence obligations does not impose exactly the same obligations on every company in a supply chain. The level of obligation depends on the company’s role, its position in the supply chain, whether the relevant product is already covered by a Due Diligence Statement (DDS) or simplified declaration, and whether the company is an SME or non-SME. The examples below translate the company-role scenarios in the EUDR Supply Chain Infographics into practical business situations.

Key Takeaways

• EUDR obligations depend on the company’s role in the supply chain, whether it is upstream or downstream, and whether it is an SME or non-SME.
• Upstream operators carry the core due-diligence responsibility, including completing due diligence and submitting the required DDS before placing relevant products on the EU market or exporting them.
• Downstream operators and traders generally do not repeat the full upstream due-diligence process; their obligations focus on the applicable traceability, Information System and reference-information requirements.
• Micro and small primary operators in qualifying low-risk situations can use the simplified declaration mechanism, rather than submitting a standard DDS for every transaction.
• DDS reference numbers and supplier/product information remain important downstream, allowing companies to maintain the link between incoming products and the upstream EUDR process.
• The key operational challenge is maintaining connected records across suppliers, plots, products, transactions, evidence and EUDR references—not treating compliance as a standalone DDS submission.
• Technology can help apply the correct workflow by company role, reducing unnecessary duplication while maintaining traceability and audit-ready records.

What Are EUDR Due Diligence Obligations?

EUDR due diligence is the process used by an operator to establish that relevant products are deforestation-free, produced in accordance with the relevant legislation of the country of production, and subject to the required EUDR process. For an upstream operator, this means collecting the required information, assessing risk, taking risk-mitigation measures where necessary, and submitting the applicable DDS before placing the relevant product on the EU market or exporting it. The European Commission’s current framework also distinguishes downstream obligations from the original upstream due-diligence responsibility.

Understand how EUDR due diligence works across different company roles, from supplier and geolocation data to risk assessment, mitigation, traceability, and DDS requirements.

Read our complete guide to EUDR Due Diligence →

1. Upstream Operator: Full Due Diligence + DDS

Practical example: A Dutch company imports coffee beans from Brazil for the first time into the EU.

The Dutch importer purchases green coffee from a Brazilian supplier and is the first company placing the imported relevant product on the EU market. The coffee has not previously been covered by an EUDR declaration.

In this scenario, the importer is the upstream operator. It carries the main due-diligence responsibility. It needs to complete the applicable due-diligence process, submit the DDS, assume responsibility for compliance, keep the relevant record and provide the DDS reference information downstream.

In practical terms, the company needs a process that connects supplier information, production information, geolocation, deforestation-free evidence, legality evidence, risk assessment, mitigation where required, and the DDS submission.

TraceX EUDR Solutions helps the Dutch importer digitally manage supplier data, plot geolocation, deforestation and legality evidence, risk assessment, and mitigation in one workflow.
It then connects this evidence to the shipment and DDS, making due diligence and downstream DDS reference management easier and audit-ready.

Understand the responsibilities of upstream operators under EUDR, including due diligence, geolocation, deforestation checks, risk assessment, mitigation, and DDS submission.

Read our complete guide to EUDR Upstream Operator Requirements

2. Upstream Micro or Small Primary Operator: Simplified Declaration

Practical example: A small coffee farmer in a low-risk EU country grows coffee and sells it directly into the EU market.

If the farmer meets the conditions for an upstream micro or small primary operator (MSPO), the simplified declaration mechanism can apply instead of submitting a standard DDS for every transaction. The farmer remains responsible for ensuring that the product meets the applicable EUDR requirements.

This is particularly relevant when designing supplier onboarding: a system should distinguish a qualifying MSPO from a company that has the full upstream operator role rather than applying one identical workflow to every supplier.

TraceX can identify and onboard qualifying MSPO suppliers through a simplified workflow, capturing their required production, plot and geolocation information.
It can then maintain this data and declaration records in a centralized traceability system, making supplier compliance easier to manage and verify

3. First Downstream Operator/Trader – Non-SME

Practical example: A large chocolate manufacturer in Belgium buys cocoa already covered by a DDS.

The Belgian manufacturer buys cocoa from an upstream supplier and uses it to make chocolate. The cocoa has already been covered by the upstream EUDR process.

The company does not conduct a new full due-diligence exercise or submit a new DDS merely because it is using the covered cocoa. As a non-SME downstream actor, it has applicable Information System, record-keeping and traceability responsibilities, including maintaining the relevant DDS reference or declaration identifier and required information.

The practical lesson is important: downstream compliance is not simply a second copy of the upstream operator’s due diligence. The company needs to preserve the link between the incoming product and the relevant EUDR reference information.

TraceX helps downstream operators link incoming cocoa batches to their supplier, DDS reference/declaration identifier, and required traceability records.
It provides a centralized, audit-ready record of EUDR information, without requiring the company to duplicate the upstream due-diligence process.

4. First Downstream Operator/Trader – SME

Practical example: A small European chocolate manufacturer buys EUDR-covered cocoa.

A small chocolate manufacturer purchases cocoa that has already been covered by the upstream supplier’s EUDR declaration and uses it to manufacture chocolate.

The company does not need to conduct its own full due diligence or submit a new DDS simply because it is downstream. It must collect and keep the required supplier information and DDS reference or declaration identifier, and act if it becomes aware of information suggesting that the product may be non-compliant.

TraceX helps SMEs capture and maintain supplier details, DDS references/declaration identifiers, and product traceability records in one place.
It can also flag compliance concerns and maintain an audit-ready history of the information linked to incoming EUDR-covered products.

5. Subsequent Downstream Operator/Trader – Non-SME

Practical example: A large supermarket chain buys packaged chocolate and sells it to consumers.

The chocolate is already covered by upstream EUDR due diligence. The supermarket is further downstream and is not the company that originally placed the relevant cocoa product on the EU market.

It does not conduct the upstream due-diligence process or submit a new DDS for the product simply because it sells the chocolate. As a non-SME, it has applicable Information System and traceability obligations.

Operationally, this means the retailer needs reliable records showing who supplied the product and the relevant EUDR reference information, rather than recreating the entire supplier-level due-diligence file.

TraceX helps retailers link each product to its supplier, DDS reference, and EUDR traceability information in one centralized system.
It provides an audit-ready record of downstream transactions and compliance data, without recreating the upstream due-diligence process.

6. Subsequent Downstream Operator/Trader – SME

Practical example: A small independent supermarket buys the same EUDR-covered chocolate.

A small independent supermarket purchases the packaged chocolate from a European distributor and sells it to consumers.

The supermarket does not conduct the upstream due-diligence process or submit a new DDS simply because it sells the covered product. Its focus is on the supplier/customer information and other obligations applicable to its SME downstream role, including acting when it becomes aware of information suggesting possible non-compliance.

TraceX helps SMEs capture and maintain supplier/customer information and relevant EUDR product records in one centralized system.
It also helps flag potential compliance concerns and maintain an audit-ready traceability trail for the products they handle.

Coffee Example: From Farm to Supermarket

Brazilian coffee farmer → Brazilian exporter → Dutch coffee importer → German coffee roaster → German supermarket.

The Dutch coffee importer can be the upstream operator when it is the first company placing the imported coffee on the EU market and the product is not already covered by due diligence. It carries the main due-diligence responsibility and submits the DDS.

The German coffee roaster can fall under downstream operator rules when the coffee is already covered by the upstream DDS, rather than repeating the full upstream due-diligence process.

The German supermarket’s obligations depend on its role as a trader and whether it is an SME or non-SME.

Cocoa Example: From Cocoa to Chocolate

Cocoa farmer → cocoa exporter → EU cocoa importer → chocolate manufacturer → supermarket.

The EU cocoa importer can be the upstream operator and therefore carries the main due-diligence responsibility and submits the DDS.

The chocolate manufacturer can be a downstream operator when the cocoa is already covered by the upstream DDS.

A large supermarket can have the applicable non-SME trader obligations, while a small supermarket has the applicable SME-level obligations.

EUDR Due Diligence Obligations: Quick Comparison

Why Company Role Matters for EUDR Compliance

A common implementation mistake is to treat EUDR compliance as one identical checklist for every company in the supply chain. The role-based model shows why that approach can create unnecessary work or leave gaps. An importer acting as the upstream operator needs a substantially different workflow from a downstream retailer that receives products already covered by an upstream declaration.

For businesses, the practical starting point is therefore to map each product flow: Who is the upstream operator? Has the relevant product already been covered by a DDS or simplified declaration? Which companies are downstream operators or traders? Is each relevant company an SME or non-SME? Once these questions are answered, the appropriate data, reference management and compliance workflow can be designed.

How Technology Can Operationalise These Obligations

EUDR compliance becomes easier to manage when role-specific obligations are built into the supply-chain workflow. A digital compliance platform can connect supplier onboarding, plot and geolocation data, evidence, risk assessment, DDS or declaration references, product records and downstream traceability in one system.

For example, an upstream coffee importer can manage supplier and plot data through to DDS preparation, while a downstream chocolate manufacturer can focus on maintaining the incoming DDS reference and linking it to its products and transactions. This avoids treating every company as though it has the same compliance responsibility.

TraceX EUDR Solutions help businesses operationalise these role-specific obligations by connecting supplier onboarding, plot-level geolocation, deforestation checks, risk assessment, evidence, traceability, and DDS management in one platform. This allows upstream operators to build due diligence from source to DDS, while downstream operators can track incoming products, maintain DDS references, and preserve an audit-ready compliance trail without duplicating upstream due diligence.

EUDR Due Diligence Obligations Checklist

• Identify your role in each EUDR-relevant supply chain.
• Determine whether you are an upstream operator, upstream MSPO, downstream operator or trader.
• Check whether the relevant product is already covered by a DDS or simplified declaration.
• Determine whether the applicable company is an SME or non-SME.
• Capture and retain the EUDR information and reference identifiers applicable to your role.
• Build a process for responding to information suggesting possible non-compliance.
• Keep product, supplier and transaction records linked so the compliance trail can be demonstrated.

Conclusion

Understanding EUDR due diligence obligations starts with understanding the company’s role. The practical difference between an upstream operator, an MSPO, a downstream manufacturer and a trader can determine whether the business needs to perform full due diligence, submit a DDS, use a simplified declaration, or primarily maintain traceability and reference information.

For companies preparing for EUDR implementation, the goal should be more than collecting documents. The objective is to build a traceable, role-specific compliance process that connects suppliers, products, declarations, references and transactions.

Frequently Asked Questions