EUDR Requirements for Operators and Traders: A Practical Guide to Compliance

Under the EUDR, operators must collect geolocation data, verify legality and deforestation-free status, and submit Due Diligence Statements (DDS) before placing products on the EU market. Traders are required to store and pass on DDS reference numbers and maintain records for five years. Both roles must ensure full traceability and compliance throughout the supply chain.  

With the EU Deforestation Regulation (EUDR) now in force, companies that fail to comply risk shipment blocks, regulatory penalties, and even losing access to premium EU markets. Buyers are demanding proof—not promises—when it comes to deforestation-free sourcing. 

But for operators and traders, relying on manual processes, spreadsheets, and fragmented documentation simply won’t scale. As complexity increases across suppliers, countries, and commodities, manual compliance becomes a bottleneck—and a liability. 

Key Takeaways 

• Operators and traders under the EU Deforestation Regulation (EUDR) have distinct roles. Operators must collect geolocation data, verify legality, assess deforestation risks, and submit a Due Diligence Statement (DDS) via the EU TRACES system. Non-SME traders are also obligated to submit DDSs, while all traders must maintain and share supplier records and DDS reference numbers. 

• The DDS must include specific data fields such as product type, country of origin, polygon or point coordinates, and a documented risk assessment. Mistakes in DDS preparation or missing documentation can result in rejected shipments or penalties. 

• Digital traceability platforms simplify compliance by validating GeoJSON data, digitizing supplier onboarding, automating DDS creation in EU-compliant formats (JSON/XML), and scoring deforestation risks using satellite and benchmark datasets. 

• TraceX’s EUDR Compliance Platform offers end-to-end support—from farm-level onboarding and geolocation mapping to DDS generation and TRACES submission—ensuring operators and traders meet EUDR requirements with confidence. 

Who Is an Operator vs. a Trader? 

Understanding Your Role Under EUDR 

Under the EU Deforestation Regulation (EUDR), clarity on whether you’re classified as an Operator or a Trader is critical—because it defines your legal obligations, risk exposure, and documentation duties. 

As per the EUDR official text,  

Operator is 

“Any natural or legal person who places on the market or exports relevant products in the course of a commercial activity”. 

For relevant products produced according to Article 2(14) within the EU: 

• This can include producers or manufacturers. 

•  Additionally, any entity that transforms a relevant product into another—resulting in a new HS code as defined in the regulation—and then places it on the market or exports it, is considered an operator further down the supply chain. 

For relevant commodities or relevant products produced outside the EU: 

• Under the EU Deforestation Regulation (EUDR), the “operator” is typically the importer responsible for declaring relevant commodities or products for customs clearance into the EU. 

•  If the importer is not based in the EU, the first entity that makes the products available on the EU market is considered the operator. This ensures that there is always an accountable party within the EU, even if the original importer is established outside the Union. 

Let us take an example: 

For example, if Company X, based in Ghana, exports cocoa butter to Europe, and Company A, based in the EU, imports it, the EUDR would consider only Company A as an operator. Additionally, if Company B, also based in the EU, uses that cocoa butter to produce chocolate and places it on the market, Company B will be considered an operator because it has created a new product with a different HS code from the original cocoa butter. Finally, Company C, based in the EU, which buys chocolate from Company B and exports it outside Europe, also qualifies as an operator. 

As per the EUDR Official text, 

Trader is: 

“Any [natural or legal] person in the supply chain, other than the operator, who makes relevant products available on the market in the course of a commercial activity”. 

Under the EUDR, due diligence obligations for traders depend on their size.  

• Non-SME traders must ensure that due diligence was performed upstream, similar to operators.  

• SME traders, however, are not required to conduct due diligence themselves but must maintain traceability. They need to keep records of supplier and client information, as well as due diligence reference numbers, and provide this information to authorities upon request to demonstrate compliance. 

Considering an example, 

With respect to the cocoa companies, Company D, which buys chocolate from Operator B in the EU and distributes it to supermarket chains without transforming it, is considered a trader. 

Understanding these roles and their respective responsibilities under the EUDR is the first step for Operators and Traders to navigate the new regulations effectively. 

The EU Deforestation-free Regulation mandates that operators and non-SME traders must carefully examine their supply chains to ensure that the relevant commodities are not associated with deforestation, forest degradation, or illegal activities. This involves gathering necessary information, performing a risk assessment, and submitting a due diligence statement. Conversely, SME traders are only required to retain specific information about their supply chains and provide it to market operators or authorities upon request.

Ready to Stay Ahead of EUDR Compliance? 
Explore our expert blogs to understand how to navigate evolving regulations: 

[What is EUDR Due Diligence?] – Understand the core obligations and how to get started 
[Your Guide to EUDR Compliance] – Step-by-step insights for operators and traders 

EUDR (Article 8) requirements for Operators and non-SME traders 

Data Collection 

This involves collecting detailed information about the journey of your products. This data should include the geographical location where the raw materials were initially grown or harvested (e.g., farm, plantation) and the timeframe of this primary production. 

Risk Assessment 

Once you have gathered the supply chain data, the next step is to analyze it to assess the risk of your products being linked to deforestation, forest degradation, or illegal activities (including human rights violations). This assessment should determine whether the risk is “non-negligible” (meaning there’s a real possibility of these issues) or “negligible” (meaning the risk is very low). 

• Non-negligible Risk: If the assessment identifies a non-negligible risk, you cannot simply place the products on the market. Instead, you must take steps to mitigate (reduce) these risks before they become compliant with the EUDR. 

• Negligible Risk: If the assessment finds either negligible risk or no risk at all, your products are considered compliant with the EUDR and can be freely marketed. 

Risk Mitigation 

If you identify non-negligible risks during your assessment, you need to take action to reduce them to a negligible level. This might involve: 

• Obtaining More Information: You may need to request further details from your suppliers or conduct additional research to gain a clearer picture of their practices. 

• Independent Verification: Consider independent surveys, laboratory analysis of materials, or field audits to confirm your suppliers’ claims and identify any potential issues. 

• Supplier Training: Providing training programs for your suppliers can help improve their practices and reduce deforestation risks throughout your supply chain. 

• Supply Chain Interventions: Depending on the identified risks, you may need to implement interventions within your supply chain to promote sustainable practices and eliminate illegal activities. 

EUDR Obligations for Operators: Explained 

Under the EU Deforestation Regulation (EUDR), Operators—those placing commodities or products on the EU market for the first time—are responsible for proving that their sourcing is deforestation-free and legal. Here’s what they must do: 

Collect and Verify Geolocation Data 

Operators must obtain farm- or plot-level geolocation coordinates (as points or polygons) for every production area associated with their product. 

• Polygon mapping is required for plots ≥4 hectares. 

• These coordinates ensure traceability and allow authorities to cross-check against deforestation datasets. 

Validate Legality and Deforestation Status 

Operators must prove that the land: 

• Was not deforested after December 31, 2020, using satellite evidence or historical land use analysis. 

• Is legally used for cultivation, with proper documentation like land titles or use rights. 

Submit a Due Diligence Statement (DDS) 

Before any product is placed on the EU market, Operators must: 

• Prepare and submit a DDS via the EU TRACES portal, confirming: 

• No deforestation occurred post-2020. 

• Legal compliance of sourcing. 

• Geolocation and supply chain data are accurate and complete. 

• The DDS must be product-level and shipment-specific, and is legally binding. 

Failure to meet these obligations can result in rejected shipments, fines, or being blacklisted by buyers. Digital traceability and remote sensing tools are crucial to streamline this complex process and avoid manual errors. 

EUDR Obligations for Traders: What You Need to Know 

Under the EU Deforestation Regulation (EUDR), traders—those who buy and sell relevant commodities already placed on the EU market—have lighter, yet essential obligations to support traceability and legal sourcing. 

Maintain and Pass On DDS Reference Numbers 

Traders must collect Due Diligence Statement (DDS) reference numbers from their suppliers and pass them downstream to the next entity in the supply chain. 

• These references prove that the product has already undergone deforestation-free checks. 

• Traders do not need to create a new DDS, unless they place the product on the market themselves (see below). 

Store Records for 5 Years 

All relevant documents, supplier information, and DDS references must be stored securely for at least five years. 

• This includes batch tracking, transaction logs, and product identifiers. 

• Traders must make these records available upon request by authorities. 

When Does a Trader Become an Operator? 

A trader becomes an operator if they: 

• Import a product into the EU for the first time, or 

• Transform or package a product before placing it on the market under their own brand. 
  In such cases, they take on full due diligence responsibilities, including geolocation verification and DDS filing. 

 
Even without submitting DDS, traders play a critical role in maintaining supply chain transparency. Failing to manage documentation can disrupt market access or lead to compliance penalties. 

Use Case Scenarios: EUDR Compliance in Action for Operators and Traders 

To understand how EUDR obligations play out in the real world, it helps to break down responsibilities by role and use case. Below are examples of how operators and traders engage with EUDR requirements across typical supply chain situations: 

Use Case 1: Direct Importer of Green Coffee (Operator) 

Scenario: 
An EU-based roaster sources green coffee beans from smallholders in Ethiopia via cooperatives. The roaster imports the product directly. 

EUDR Obligations: 

• Collect GPS polygon data of farm plots. 

• Validate land use against deforestation after 2020. 

• Ensure documentation includes farmer consent and legality of sourcing. 

• Submit Due Diligence Statement (DDS) via TRACES before import. 

Compliance Tip: 
Use a digital platform to geo-map smallholder plots, manage certifications, and automate DDS submission. 

Use Case 2: Indonesian Timber Aggregator (Trader, Possibly Operator) 

Scenario: 
A non-SME trader aggregates timber from forest harvesters and supplies EU manufacturers. 

EUDR Obligations: 

• If the trader does not import directly, they must maintain and share the DDS reference numbers received from upstream operators. 

• If the trader places products on the EU market, they act as an operator and must file their own DDS. 

Compliance Tip: 
Ensure all DDS reference numbers from suppliers are valid and verified. Keep documentation for a minimum of 5 years. 

Use Case 3: Rubber Product Manufacturer in EU (Trader / Operator) 

Scenario: 
An EU-based tire manufacturer sources processed rubber from Asia and uses it in production. 

EUDR Obligations: 

• If sourcing directly, must file DDS. 

• If purchasing from another EU operator, must track and store the DDS reference number. 

• Ensure traceability back to the sourcing plot. 

Compliance Tip: 
Set up workflows that link material invoices to DDS IDs and flag any missing documentation in real time. 

What Must the Due Diligence Statement (DDS) Contain? 

Under the EUDR, a Due Diligence Statement (DDS) is a legally required digital submission that proves the product’s compliance with deforestation-free and legal sourcing requirements before being placed on the EU market. 

Mandatory DDS Fields 

The DDS must include specific data fields to demonstrate traceability and risk assessment: 

• Geo-coordinates of farm plots (point or polygon format, ≥0.5 ha must be polygon) 

• Country of production 

• Commodity and product type 

• Operator/trader identity and role 

• Assessment of risk, including: 

• Deforestation status 

• Legal compliance (land tenure, labor rights, environmental laws) 

• Mitigation measures if risk isn’t negligible 

Accepted File Formats & Submission Protocols 

• The DDS must be generated in JSON or XML format as per EU TRACES schema requirements. 

• It is submitted through the EU TRACES portal, either manually or via API integration (for high-volume operators). 

• One DDS must be filed per shipment, not per supplier.

The DDS isn’t just a form—it’s your legal passport to the EU market. Investing in clean, complete data and automation can prevent costly rejections or delays. 

How Digital Platforms Help Operators and Traders Comply with EUDR 

Digital platforms are essential for simplifying and scaling EUDR compliance—especially for operators and traders managing complex, multi-tier supply chains. Here’s how they help: 

GeoJSON Validation Tools 

Platforms validate geolocation data (points and polygons) against EU-compliant geometry standards. This ensures that mapped farm plots meet the EUDR’s accuracy requirements, reducing the risk of DDS rejection due to faulty spatial data. 

Supplier Onboarding with KYC + Certification Uploads 

Digital platforms streamline supplier registration by: 

• Capturing KYC documents, land records, and consent forms in local languages 

• Aggregating organic, UEBT, RA or other certifications 

• Enabling multilingual and mobile-based data collection for smallholders 

This ensures that all actors in the chain—farmers, aggregators, traders—are verifiable and auditable.

DDS Automation with EU Schema Integration 

Automated generation of DDS files (in JSON/XML) using compliant data templates saves time and eliminates manual errors. These platforms often include direct API integration with the EU TRACES portal, enabling one-click submissions per shipment. 

Risk Scoring Dashboards Aligned with Country Benchmarks 

Platforms use AI or rule-based engines to assess: 

• Country risk (per EU benchmarks) 

• Deforestation alerts (via satellite monitoring) 

• Documentation gaps 

These dashboards help operators and traders prioritize high-risk suppliers and take mitigation actions early—ensuring compliance and audit readiness. 

How does TraceX EUDR Solutions help? 

The TraceX EUDR Compliance Platform helps operators and traders simplify and automate every step of their due diligence obligations under the EU Deforestation Regulation (EUDR).  

Verified Geolocation Mapping 

TraceX enables mobile-based GPS capture with built-in GeoJSON validation tools that ensure mapped plots comply with EU spatial data formats. Field officers can map farms offline, validate proximity to deforestation zones, and avoid DDS rejections. 

See EUDR Compliance in Action 
Discover how a Nigerian trading firm streamlined supply chain traceability, supplier onboarding, and DDS submissions using the TraceX EUDR Platform. 

[Read the Full Case Study →] 

Digital Supplier Onboarding 

The platform supports the collection of KYC documents, land ownership proofs, consent forms, and sustainability certifications (e.g., Organic, RA, UEBT). It centralizes supplier metadata—from smallholders to aggregators—into structured, searchable profiles. 

AI-Powered Risk Scoring 

TraceX’s platform automatically runs country, commodity, and supplier-level risk assessments, leveraging EU benchmark logic and satellite-based deforestation alerts. This helps companies identify non-compliant sources before shipments are blocked. 

Automated DDS Generation & Submission 

Operators can generate EUDR-compliant Due Diligence Statements (DDS) in JSON/XML formats, pre-filled with validated data. TraceX also offers direct API or export-ready submission support to the EU TRACES portal, enabling scalable compliance. 

Chain-of-Custody & Traceability 

With full lot-level traceability from farm to export, the platform ensures visibility and document governance at every tier. This is key for operators who must prove sourcing origin, legality, and chain integrity. 

Understanding EUDR Requirements Is Key to Compliance 

The EUDR requirements for operators and traders may seem complex, but understanding the responsibilities and implementing due diligence is essential for staying compliant. By keeping up with the specific obligations, maintaining accurate records, and ensuring supply chain transparency, operators and traders can contribute to sustainable trade practices. It’s about more than just compliance—it’s a commitment to preserving forests and fostering a sustainable future for global trade.

Frequently Asked Questions (FAQ’s)

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Navigating EUDR Just Got Easier 

Struggling with geo-coordinates, DDS formatting, or TRACES submissions? Explore our latest blogs to decode: 
Geolocation Requirements for EUDR Compliance
How to Submit DDS via EU TRACES
The Role of Digital Traceability in Meeting EUDR Standards