EUDR Operators vs Traders: Who Carries Which Duty

Updated 2026-11-02 · 4 min read · By the akar.earth specialist team

EUDR operator and trader duties after the December 2025 amendments: who files due diligence, what downstream firms do, and where Indonesian exporters fit.

Under the EUDR, an operator is a company that places a covered product on the EU market for the first time or exports it from the EU, and a trader makes it available on the market afterwards. Since the December 2025 amendments, full due diligence rests with the operator who first places the product on the market, while downstream operators and traders mainly collect reference numbers to keep the chain traceable.

The roles after the amendments

The Commission’s fifth implementation FAQ describes the current structure. It introduced two new categories, “downstream operator” and “micro and small primary operator”.

The FAQ is a non-binding working document. The amended Regulation is the legal source, and readers should check the definitions there, especially for company size thresholds.

Where Indonesian companies sit

The EUDR places duties on companies acting on the EU market. The Commission states that producers and companies outside the EU have no obligations under the EUDR unless they place products on the EU market themselves. They may still be asked for information, such as where products were grown.

In practice:

• Farmers, cooperatives, collectors, mills and factories in Indonesia have no direct EUDR duty. They are asked for data by their buyers.
• Indonesian exporters have no direct duty either, but they are the point where data from many suppliers is assembled. Their EU customers depend on them.
• Indonesian groups with EU subsidiaries that import into the EU are operators through those subsidiaries.

This means commercial pressure replaces legal duty. An Indonesian exporter that cannot deliver geolocation and legality evidence will lose EU orders to one that can.

What the first operator needs from Indonesia

The first operator must collect information, assess risk and mitigate it before filing. From Indonesian suppliers it typically asks for:

• Geolocation for every plot of production, as points or polygons.
• Evidence that the plots were not deforested after 31 December 2020.
• Evidence of legality under Indonesian law: land rights, permits, labour and environmental compliance.
• A description of the supply chain, including collectors and processors.
• Proof that compliant volume was kept separate. Mass balance is not accepted.

The operator stays responsible even when the supplier does the work. That is why EU buyers audit data quality, ask for satellite screening results, and sometimes send their own field teams.

The downstream chain in the EU

Take Indonesian cocoa butter. The EU importer that buys it from an Indonesian grinder is the first operator and files a statement. A chocolate maker that buys the butter in the EU is a downstream operator and records the reference number. A retailer selling the chocolate is a trader. Before the amendments, each of these had heavier duties; now the burden sits mostly at the first placement.

This concentrates scrutiny on the importer, which in turn concentrates data requests on the Indonesian exporter.

Relation to other supply chain laws

The EUDR is product-focused: it asks whether a product is compliant. The EU Corporate Sustainability Due Diligence Directive is company-focused and covers wider human rights and environmental harms. Some large EU buyers fall under both. See EUDR vs CSDDD.

Questions to ask your EU customer

• Are you the first operator for this product, or a downstream operator or trader?
• Which data fields and file formats do you need from us, and by when?
• Do you need data per shipment, per contract or per season?
• Will you share the DDS reference number with us for our records?
• How will you treat plots your screening flags, and can we provide field evidence before you decide?

Practical steps for Indonesian exporters

1. Identify which of your customers is the first operator for each product line.
2. Ask them for their data template and their risk assessment approach.
3. Build a plot register that covers your whole supply base, not just the next shipment.
4. Keep segregated flows for EU-bound volume.
5. Share data under clear agreements that respect farmer consent.

The EUDR hub gives the full topic map, and writing a due diligence statement explains what your buyer files. For help building the data your buyers need, see our EUDR compliance services or message us on WhatsApp.