Trader (EUDR)
Under the amended EUDR, a trader is any person in the supply chain, other than the operator or downstream operator, who in the course of a commercial activity makes relevant products available on the EU market. Traders keep supplier and customer information but do not submit due diligence statements.
Also known as: EUDR trader · non-SME trader
Why does it matter?
The word “trader” means different things in commodity markets and in the EUDR. In the regulation it is a legal role defined by what a company does with a product on the EU market, not by its business model. Getting the role right determines the obligations.
How does it work in practice?
A trader does not place a product on the market for the first time; it makes available a product already placed. Its obligations under the amended Article 5 match those of downstream operators:
- keep the identity and contact details of suppliers and customers for at least five years;
- when buying directly from an operator, keep the reference numbers or declaration identifiers received;
- register in the Information System if not an SME;
- inform authorities and customers of relevant new information and, if not an SME, verify due diligence in case of substantiated concerns.
The Commission’s 2026 FAQ also notes that in the cattle chain, subsequent sellers of live cattle after the first placer are traders.
Common pitfalls
- Mapping the legal role to company type (“we are a trading house, so we are a trader”) instead of to each transaction.
- Ignoring the registration obligation for non-SME traders.
Role mapping per flow is part of Farmer1st’s EUDR compliance service.
Frequently asked questions
Is a commodity trading house a 'trader' under the EUDR?
Not necessarily. A company that imports cocoa or coffee into the EU is placing it on the market and is therefore an operator. The EUDR term 'trader' refers to a person who makes products already on the EU market available, such as a distributor or wholesaler.
What changed for traders in 2025?
Before Regulation (EU) 2025/2650, non-SME traders were treated like non-SME operators. Now all traders have the same obligations as downstream operators: collect and keep information, pass it on, and act on substantiated concerns.
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