Micro or small primary operator (EUDR)
Under the amended EUDR, a micro or small primary operator is a natural person or micro or small undertaking in a low-risk country that places on the market or exports relevant products it has itself produced. It submits a one-time simplified declaration instead of due diligence statements.
Also known as: simplified declaration · declaration identifier · MSPO
Why does it matter?
Regulation (EU) 2025/2650 created this subcategory of operator to relieve farmers and foresters who sell their own production. The simplified regime is described in the new Article 4a and Annex III of the EUDR.
How does it work?
- The operator submits a one-time simplified declaration in the Information System before placing products on the market, and receives a declaration identifier to pass to its customers.
- It may update the declaration after major changes; the Commission’s FAQ says a change in annual production volume does not require an update.
- Where all Annex III information already exists in a system or database under Union or Member State law, the Member State can make it available instead, and the operator does not submit.
- Authorised representatives such as cooperatives, associations or public bodies can submit on members’ behalf.
- Because the operator is by definition in a low-risk country, risk assessment and mitigation are only required if information points to a risk of non-compliance.
The size thresholds refer to Directive 2013/34/EU; a larger company can qualify if the business segment dealing with relevant commodities stays within the limits.
Common pitfalls
- Assuming every smallholder qualifies. The low-risk country condition is decisive; see country benchmarking.
- Confusing the declaration identifier with a DDS reference number in downstream records.
Check the latest Commission FAQ for detailed conditions before relying on the simplified regime.
Frequently asked questions
Does this category apply to smallholders in standard-risk countries?
No. The definition requires establishment in a country classified as low risk under Article 29. Smallholders in standard-risk or high-risk countries who sell to exporters are usually not operators at all; the EU importer is.
Can a simplified declaration use a postal address instead of geolocation?
Yes. Article 4a(5) allows the postal address of the plots or establishment to replace geolocation, and the Commission's FAQ adds cadastral or equivalent information as an option.
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