Operator (EUDR)
Under the EUDR, an operator is any natural or legal person who, in the course of a commercial activity, places relevant products on the EU market for the first time or exports them, excluding downstream operators. Operators must exercise due diligence and submit a due diligence statement.
Also known as: EUDR operator · upstream operator · first placer
Why does it matter?
The operator carries the core obligations of the EUDR: exercise due diligence, submit a due diligence statement, keep records for five years and pass the reference number to its customers. Since Regulation (EU) 2025/2650, the definition excludes downstream operators, so due diligence sits with the first placer on the market or the exporter.
How does it work in practice?
“Placing on the market” means the first making available of a product on the EU market. In a cocoa or coffee chain, the operator is usually the EU importer: a trader, grinder or roaster. Where the importer is established outside the EU, Article 7 deems the first EU-established person who makes the product available to be the operator.
A special subcategory, the micro or small primary operator, covers farmers and small producers in low-risk countries who place their own production on the market. They file a one-time simplified declaration instead of a statement per placement.
Common pitfalls
- Assuming the obligation belongs to the origin exporter because it holds the data. The legal duty sits with the operator, which usually needs the exporter’s data.
- Forgetting that exports from the EU are also covered.
- Missing dual roles when a company both imports and transforms.
Farmer1st helps operators obtain first-mile evidence from their supply base through its EUDR compliance service.
Frequently asked questions
Is an exporter in a producing country an EUDR operator?
Not by exporting to the EU alone. The operator is whoever first places the product on the EU market. Where that person is established outside the EU, the first person established in the EU who makes the product available is deemed the operator (Article 7).
Can a company be both an operator and a downstream operator?
Yes. The Commission's 2026 FAQ describes a dual role, for example a company that imports a relevant product (operator) and then transforms it before selling it on the EU market (first downstream operator).
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