Downstream operator (EUDR)
Under the amended EUDR, a downstream operator is any natural or legal person who, in the course of a commercial activity, places on the market or exports relevant products made using relevant products all of which are already covered by a due diligence statement or simplified declaration.
Also known as: first downstream operator · non-SME downstream operator
Why does it matter?
The category was introduced by Regulation (EU) 2025/2650 to remove duplicate filings. Before the amendment, each company transforming a relevant product could have to reference or ascertain earlier statements. Now only the first placer, the operator, files. Downstream operators have obligations identical to those of traders.
What must a downstream operator do?
Under the amended Article 5:
- Collect and keep the name, postal address, email and, if available, website of suppliers and customers, for at least five years.
- Where the supplier is an operator (a “first downstream operator” situation), also keep the reference numbers of statements or the declaration identifiers.
- Inform competent authorities and customers of relevant new information, including substantiated concerns.
- If not an SME, register in the Information System and, in case of substantiated concerns, verify that due diligence was exercised before placing products.
The Commission’s 2026 guidance states that collecting reference numbers is a passive obligation: in good faith, a downstream actor can presume a supplier is not an operator if it receives no reference number.
Common pitfalls
- Continuing to build filing workflows that the amendment made unnecessary.
- Losing reference numbers between purchasing and production systems.
Farmer1st’s data integration service connects reference numbers and origin data to the ERPs and compliance platforms companies already use.
Frequently asked questions
Does a downstream operator submit a due diligence statement?
No. Since Regulation (EU) 2025/2650, downstream operators do not submit statements or ascertain that due diligence was exercised. They collect and keep information on their suppliers and customers and, when their supplier is an operator, the reference numbers or declaration identifiers.
Must a downstream operator register in the Information System?
Downstream operators that are not SMEs must register in the EUDR Information System before placing, making available or exporting relevant products (Article 5(2) as amended).
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