Do downstream operators and traders still need an EUDR due diligence statement?

No. Since Regulation (EU) 2025/2650, a downstream operator or trader does not file a due diligence statement and does not carry out due diligence. Only the operator that first places the relevant product on the EU market, or exports it, does that. Everyone downstream instead collects and keeps a reference number, and — if it is not an SME — registers in the Information System and takes on a narrow set of monitoring duties.

That is a real change from the 2023 text, where a non-SME trader carried close to the same due diligence burden as the operator that imported the goods. The amendment did not remove the trader's obligations altogether; it replaced due diligence with traceability.

Who this actually covers

Regulation (EU) 2025/2650 formally introduces downstream operator as its own category, alongside the trader definition that was already in the 2023 regulation. Both describe a business handling a relevant product, or a product made from one, that has already been placed on the EU market under a due diligence statement or a simplified declaration filed by someone else.

• A downstream operator places on the market, or exports, a product made using a relevant product that is already covered by an upstream statement — a furniture maker buying EUDR-covered timber that has already cleared customs, for instance.
• A trader makes a relevant product available on the market without being the one who first placed it there — a distributor or wholesaler moving goods on within the EU.

Neither is the operator who first imports the raw commodity or manufactures it from EU-grown material. That operator still carries out full due diligence and still files the statement, whatever their size.

What downstream operators and traders must still do

The due diligence statement and the risk assessment behind it are gone for this group. What remains is traceability and cooperation:

• Collect and retain the reference number of the due diligence statement, or the identifier of a simplified declaration, tied to the product — but only where the direct supplier is an operator, not another downstream link (see below).
• Keep records for five years, in a form that shows which supplier and which statement a given batch of product came from.
• Register in the EU Information System, but only if the business is not an SME.
• Notify the competent authority immediately on becoming aware of information suggesting non-compliance, and cooperate with inspections — obligations that fall specifically on non-SME downstream operators and non-SME traders.
• Verify due diligence where there is a substantiated concern. If a competent authority or a third party raises a substantiated concern — a reasoned claim, backed by objective and verifiable information, that a specific product does not comply — a non-SME downstream operator or trader holding that product must check that due diligence was in fact exercised upstream and that only a negligible risk remains. If it cannot establish that, it may not place the product on the market or make it available.

None of this is filed with the Information System as a statement. It sits in the business's own records, produced on request.

The reference number obligation only bites once

This is the detail most summaries skip. The duty to collect and keep the due diligence statement reference number, or the simplified declaration identifier, applies to the first downstream operator or trader in the chain — the first business, at any size, to receive the product after the operator who filed the statement. It does not repeat at every subsequent sale.

A distributor buying from that first downstream link, three or four hands later, is not expected to chase a reference number that was never passed to it. In practice the obligation is passive beyond that first link: without a number attached to a consignment, a buyer further down the chain can reasonably assume, in good faith, that the product was not supplied directly by the operator that carries the filing duty.

This matters for two reasons. First, it means the compliance burden is genuinely concentrated near the top of the chain, not smeared evenly across every intermediary — a change worth knowing if you have been quoted a due diligence retainer priced as though you were still filing. Second, it means the one link that does hold the obligation needs a system that actually captures the number at the point of purchase, because there is no second chance further downstream to reconstruct it.

SME status decides more than it used to

Before the amendment, the SME/non-SME line mattered mainly for traders. Now it decides registration and monitoring duties for downstream operators too.

Obligation	SME downstream operator or trader	Non-SME downstream operator or trader
File a due diligence statement	No	No
Register in the Information System	No	Yes
Collect and retain reference numbers (first link only)	Yes	Yes
Keep five-year records	Yes	Yes
Notify authorities of known non-compliance	Not specified	Yes
Verify due diligence on a substantiated concern	Not specified	Yes

Size is assessed the same way as everywhere else in the regulation — the thresholds in Directive 2013/34/EU, applied to the individual business or, where relevant, its group. How company size is worked out covers the test in full, because it is the same test that decides which application date applies to an operator further up the chain.

Where this sits against the rest of the chain

Position in the chain	Files a DDS	Registers	Collects reference numbers	Runs risk assessment
Operator placing product on EU market first	Yes	Yes	N/A — issues the number	Yes
First downstream operator or trader after that	No	Non-SME only	Yes	No
Every downstream operator or trader after the first	No	Non-SME only	No	No

The operator in the top row is the only one whose obligations are unchanged from the original 2023 text in substance. What changed under Regulation (EU) 2025/2650 sets out the rest of that amendment, including the postponed application dates and the concessions for micro and small primary operators.

Why the change was made

Under the 2023 regulation, a chain with several EU intermediaries between the importer and the final retailer could generate a due diligence statement at every step, each one reasserting a risk assessment about the same underlying consignment. That duplicated paperwork without adding a new check — the risk was already assessed once, upstream, against the same plot data. Concentrating the filing on the first placer removes the duplication while keeping a traceable link, via the reference number, running down the chain.

What this does not mean

Being a downstream operator or trader is not an exemption from the EUDR. It is a lighter, traceability-based obligation rather than no obligation. Get the categorisation wrong — treat yourself as downstream when you are in fact the first business to place a product on the EU market, for example because you import a semi-finished component and finish it in the EU — and you are exposed to the full due diligence and filing duty you assumed did not apply to you.

The general penalty regime is also unaffected by which category you fall into: fines with a maximum of at least 4% of annual EU-wide turnover, confiscation of products and of revenues derived from them, and exclusion from public procurement apply across the regulation, not just to operators who file statements.

How to check your own position

Three questions settle it for most businesses:

1. Are you the first business to place the relevant product, or a product made from it, on the EU market — or do you export it from the EU? If yes, you are an operator and you file.
2. If not, are you the first business after that operator to receive the product? If yes, you must collect and keep the reference number, whatever your size.
3. Are you an SME? If not, add registration, notification and cooperation duties to whatever traceability obligation applies.

Getting the geolocation and cut-off date requirements right matters only to the operator actually filing — but everyone downstream should know what a valid statement looks like, since the step-by-step guide to filing a due diligence statement in TRACES and the geolocation rules behind it explain what your supplier's reference number is actually standing behind.

Check what the EUDR requires of your specific business — including whether you are an operator, a downstream operator, or a trader, which is the question this page cannot answer without knowing where you sit in your own supply chain.