The role you hold decides what you file and what you only keep. This page separates the first operator from the downstream actors and sets out the two application dates.
Summary
Regulation (EU) 2025/2650 simplified the chain. Only the operator that places the product on the market or exports it submits the due diligence statement. Downstream operators and traders do not file statements of their own.
That does not make them free of duties. They collect and keep the name and contact details of their suppliers and customers and, where the supplier is an operator, the reference number of its statement. Non-SME downstream operators and traders must also register in the information system.
Two dates apply: 30 December 2026 in general, and 30 June 2027 for natural persons and micro or small undertakings established as such by 31 December 2024, except for timber products. Check which date applies to you before you plan the work.
Operator, downstream operator and trader: who is who
The operator is the company that places a relevant product on the Union market for the first time, or exports it. A downstream operator buys products that were already placed on the market and uses them in its own activity, for example a printer that converts paperboard into cartons. A trader makes products available without changing them, as a wholesaler or distributor does.
One company can be several of these at once. A converter that imports its own paperboard is an operator for that import and a downstream operator for the board it buys in the Union. Decide the role per product line, not per company.
Who files the statement
The statement is filed by the operator before the product is placed on the market or exported. Its content covers the product, the country of production and the geolocation of the plots, as set out in the guides on geolocation and on filing in TRACES NT.
If you are not sure whether you are the first operator, ask your supplier for the reference number of the statement that covers your goods. If there is none, you may be the operator yourself.
Passing reference numbers down the chain
The duty to collect reference numbers is narrow: Article 5(3)(a) requires them only where the supplier is an operator, so in practice the first downstream operator or trader collects them. Actors further down record the identity of their supplier and customer. We still recommend that every delivery note or invoice carries the reference number, so that the link is not lost.
Check that the number is present on the document and that the product description matches the goods. If you learn of information indicating that a product is at risk of not complying, Article 5(5) requires you to inform the competent authorities and your customers without delay.
Need to verify your EUDR compliance?
We check your tariff codes, plot geolocation and batch traceability against the EUDR obligations, and prepare the due diligence statement for you. Send us your product and supplier list and we will tell you where the gaps are.
What a trader keeps, and for how long
Traders and downstream operators keep the information on suppliers and customers for at least five years from the date of placing or making available on the market or export, and provide it to competent authorities on request (Article 5(4)).
Deadlines: 30 December 2026 versus 30 June 2027
Operators and traders apply the Regulation from 30 December 2026 (Article 38(2)). Natural persons and micro or small undertakings established as such by 31 December 2024 apply it from 30 June 2027, except as regards the timber products covered by the annex to the Timber Regulation, for which 30 December 2026 applies (Article 38(3)).
Size is judged by the thresholds of the accounting directive, Directive 2013/34/EU. Confirm your category, and the date on which you were established, before you rely on the later date.
Obligations by role
| Article | Obligation | Who | Date rule |
|---|---|---|---|
| 4, 33 | File the due diligence statement and obtain the reference number. | Operator (first placing on the market or export) | From the application date that applies to the company. |
| 2, 4 | Collect and keep supplier and customer information; pass on the reference number. | Downstream operators and traders | From the application date that applies to the company. |
| 5(3)-(4) | Keep the supplier and customer information for at least five years and provide it to authorities on request. | Traders and downstream operators | From the application date that applies to the company. |
| 5(2) | Register in the information system before placing, making available or exporting. | Non-SME downstream operators and non-SME traders | From the application date that applies to the company. |
| 4, 9 | Keep the statement and supporting information for five years. | Operator | From the application date that applies to the company. |
| 38 | Regulation applies to operators and traders in general. | Operators and traders | 30 December 2026. |
| 38 | Later date for natural persons and micro or small undertakings established by 31 December 2024; not for timber products. | Micro and small operators | 30 June 2027. |
Role by position in the supply chain
| Position | Example (HS/CN) | Role | Files a statement |
|---|---|---|---|
| Importer of paperboard | HS 48 | Operator | Yes |
| Carton converter buying board in the Union | HS 4819 | Downstream operator | No, keeps the reference number |
| Wholesaler of coffee | HS 0901 | Trader | No, keeps records |
| Exporter of beef | HS 0201 | Operator (export) | Yes |
Application dates
Dates are listed as the Regulation states them. The status of each date is calculated when you open the page.
30 December 2026
General application date
- The Regulation applies to operators and traders in general. (Article 38)
30 June 2027
Micro and small operators
- The later date applies to micro and small operators established by 31 December 2024, except for timber products. (Article 38)
Exemptions and later dates
Two groups follow different rules.
- Micro and small primary operators file a one-time simplified declaration and, if established by 31 December 2024, may use the date of 30 June 2027 (not for timber products).
- Low-risk country sourcing does not remove the duty to file; it simplifies risk assessment and mitigation only.
Acts that can change the roles
We have not verified the adoption status of these acts.
- Commission simplification review, due by 30 April 2026, which may lead to further changes before the application date.
Frequently asked questions
Does a downstream trader submit its own DDS?
No. Under Regulation (EU) 2025/2650 only the operator that places the product on the market or exports it submits the statement. Downstream operators and traders collect and keep information (Article 5).
What are the application dates?
30 December 2026 in general. 30 June 2027 for natural persons and micro or small undertakings established as such by 31 December 2024, except for timber products, for which 30 December 2026 applies (Article 38).
Book a 15-minute EUDR audit
We look at your product list, tariff codes and plot data and tell you where the gaps are. Write to us through the contact page; a booking slot is offered here when it is available.
Sources
- Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on deforestation-free products (EUDR), OJ L 150, 9.6.2023. Read in the Official Journal text on 10 November 2026.
- Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115 (application dates, downstream operators, simplified declaration, scope). Read in the Official Journal text on 10 November 2026.
- Legal commentary and Commission guidance as reported by law firms (EY, Linklaters, VinciWorks, Lexgo), read on 10 November 2026. Indicative only.
Facts last checked against the Official Journal text on 10 November 2026.
This page is general information, not legal advice. It reflects the Official Journal text of Regulation (EU) 2023/1115 as amended and Commission guidance as read on 10 November 2026; items marked as expected are not confirmed. Obligations depend on your role, product and Member State. Check the current official text on EUR-Lex.