akar.earthOperator: Definition
What is an operator under the EUDR? Who counts as an operator, what due diligence they owe, and how this differs from a trader for Indonesian supply chains.
An operator, under the EU Deforestation Regulation (EUDR), is any natural or legal person who, in the course of a commercial activity, places a covered product on the EU market or exports it from the EU. Operators carry the main due diligence duty and must submit a due diligence statement before the product enters the market.
Why it matters
Operator status decides who is legally responsible. The operator must collect geolocation and supply chain information, assess and mitigate risk, file the due diligence statement and keep records. Penalties for non-compliance can include fines, confiscation of products and exclusion from public procurement.
How it works in practice
- An EU company importing Indonesian coffee, cocoa or palm oil and releasing it for free circulation is typically the first operator.
- A manufacturer that turns covered raw material into a covered derived product and places it on the market may also be an operator.
- Following the December 2025 amendments, the Commission says full due diligence sits with the first operator, and downstream operators and traders mainly need to keep and pass on references. Check the latest guidance.
- Timelines differ by size: the Commission gives 30 December 2026 for large and medium operators and 30 June 2027 for micro and small enterprises, with exceptions for those already under the EU Timber Regulation.
Indonesia and Southeast Asia angle
Indonesian firms are usually suppliers to operators, not operators themselves, unless they have an EU entity. Their commercial position still depends on meeting the operator’s data needs. Some Indonesian groups with EU subsidiaries are operators in their own right. See operators and traders.
For suppliers, the practical question is simple: can you give your EU customer everything it needs to file a due diligence statement quickly? That means plot geolocation, a clear link between plots and each shipment, and evidence of legal production.
Common mistakes
- Assuming only the importer has obligations and suppliers can wait.
- Confusing customs declarant with operator.
- Ignoring derived products listed in the annex.
Start at the EUDR hub.
Frequently asked questions
Is an Indonesian exporter an EUDR operator?
Normally not, because operator status depends on placing products on the EU market or exporting from it. The EU importer that first places the goods on the market is usually the operator.
What changed for operators in the December 2025 amendments?
The Commission's updated FAQ says full due diligence now rests with the operator that first places the product on the EU market, while downstream operators and traders have lighter obligations. Check the Commission page for the current text.