Operator and trader are the two roles the EUDR assigns to companies in the supply chain, and they carry very different obligations. Operators run due diligence and file statements; traders mostly document reliance. Getting the classification wrong, in either direction, means either unlawful shortcuts or expensive work you never owed.
A practical preparation workflow
- 1
Determine the activity: placing on the market or exporting means operator duties.
- 2
For downstream making-available, record supplier identities and DDS reference numbers.
- 3
Re-check the role when products, activities, or company size definitions change.
Operator: the one who answers for due diligence
An operator is whoever places a covered product on the EU market or exports it. That makes the importer an operator, and it also makes an EU manufacturer who incorporates covered inputs an operator for those inputs, and an EU producer exporting covered goods an operator for the export. Operators carry the full obligation stack: collect the Article 9 information including plot geolocation, run the Article 8 risk assessment, mitigate identified risk, and submit the DDS before market placement or export.
Trader: documenting reliance instead of repeating it
A trader makes covered products available on the market without being the one who placed or exported them: distribution, resale, holding and passing on goods downstream. A trader does not re-run the operator's due diligence. The trader's duty is informational, keep and pass on the supplier identity and the DDS reference numbers behind the goods, so reliance stays traceable. A retailer selling to final consumers is typically a trader, not an operator.
The SME simplification and its limits
Traders that qualify as micro or small enterprises get a lighter information set: for each product, who supplied it and to whom it was made available, and how the relevant due diligence statement can be identified. The simplification changes the paperwork, not the principle, reliance must still be documented, and it does not transform a trader into something that can skip records entirely. Company size also feeds the application timetable, so size and role questions interact with the deadline page.
Where companies get it wrong
The classic errors: assuming an importer is a trader because it only resells; assuming a manufacturer is outside scope because it buys inside the EU; treating the trader's lighter duties as no duties; and letting a size-category change pass without revisiting the timetable and the role. Each error is avoidable with one discipline: classify per transaction from the activity, the contractual position, and the product, then record the basis.
Both roles keep records for five years
Operators and traders alike must keep their records for five years. For operators that means the evidence behind every filed statement; for traders, the linkage of goods to suppliers and reference numbers. The free Scope Checker on this site gives a preliminary role and scope read from the activity, codes, and company facts you enter, with its reasoning visible.
What to check
- Placing, making available, or exporting
- Company size category and establishment date
- Information duties matched to role
- Five-year record retention
Role classification depends on contractual and factual detail; a comparison page cannot decide it for a specific transaction.
Questions teams ask
Is an importer an operator or a trader?
An importer places products on the EU market, so it is an operator with full due diligence and DDS obligations.
Do traders need to submit a DDS?
Generally no; traders record and pass on the reference numbers of the statements behind the products they make available.
What do micro and small traders have to record?
Who supplied each product, to whom it was made available, and how the relevant DDS can be identified.
How long must records be kept?
Five years, for both operators and traders.