Trader: Definition

Updated 2026-11-02 · 2 min read · By the akar.earth specialist team

What is a trader under the EUDR? How traders differ from operators, what records they must keep, and what it means for Indonesian commodity supply chains.

A trader, under the EU Deforestation Regulation (EUDR), is any person in the supply chain, other than the operator, who makes a covered product available on the EU market in the course of a commercial activity. Traders buy and sell goods that are already on the EU market rather than placing them there for the first time.

Why it matters

The trader category decides how much due diligence a company owes. Operators carry the core risk assessment. Traders mostly need to be able to show where their goods came from and to whom they went, so that authorities can trace any product back to a due diligence statement.

How it works

• Traders must collect and keep information on their suppliers and customers and the related due diligence statement references.
• The Commission’s FAQ, updated after the December 2025 amendments, says downstream operators and traders now face lighter obligations, with full due diligence resting on the first operator.
• Traders must still act if they have information that a product may be non-compliant.

Because rules have changed more than once, check the current Commission guidance before finalising compliance plans. Our page on operators and traders explains the roles in more detail.

Indonesia and Southeast Asia angle

Southeast Asian trading houses, Indonesian exporters and Singapore-based merchants are not EUDR traders unless they act on the EU market. In practice, the word “trader” in Indonesian commodity chains often means a local collector (pengepul) or exporter. Those actors are crucial for traceability, because they are where plot-level data from smallholders usually gets lost.

Size also matters. EUDR distinguishes small and medium-sized enterprises from larger companies in some obligations, so a trading company should check which category it falls into under the latest rules.

Common mistakes

• Confusing the commercial meaning of trader with the EUDR legal category.
• Assuming traders have no duties at all.
• Losing due diligence reference numbers when goods are split or repackaged.

Start at the EUDR hub.