EUDR for EU Importers: Operator Duties, Step by Step
Are you an EUDR operator, downstream operator or trader? What EU importers must do before placing coffee, cocoa or wood on the market, step by step.
If your company is the first to place coffee, cocoa, wood, palm oil, soya, rubber or cattle products on the EU market, usually as the importer, the EU Deforestation Regulation (EUDR) makes you the operator. Before the goods are released, you do due diligence, file a due diligence statement in the EU's Information System, and give its reference number to customs and to your first customer. It applies from 30 December 2026, with a later date for some micro and small operators.
This guide is for EU importers, roasters, chocolate makers and timber buyers working out their role and what to do first. The regulation as a whole is in what is the EUDR; the full compliance list is in the EUDR compliance checklist.
Checked 21 October 2026: against Regulation (EU) 2023/1115 as amended by
Regulation (EU) 2025/2650, the Commission's
FAQ and its
Information System page. A plain-language summary, not legal advice.
Are you an operator, a downstream operator or a trader?
| Your company | Role | Files a statement? |
|---|---|---|
| Imports green coffee or cocoa beans and releases them into the EU | Operator (Article 2(15)) | Yes, before release |
| Buys from an EU importer and roasts, or makes chocolate (the customs code changes) | Downstream operator (Article 2(15b)) | No; keeps records |
| Buys and resells without changing the product, such as a wholesaler or supermarket | Trader (Article 2(17)) | No; keeps records |
| Buys in the EU from a company established outside the EU that placed the goods | Treated as an operator (Article 7) | Yes |
One company can hold several roles, depending on the product (FAQ 3.8). A scope checker walks through the questions for your products.
What must an operator do before placing goods on the market?
- Due diligence for each product (Articles 8 to 11): collect the information, assess the risk, and mitigate it until it is negligible. The information is always required. Simplified due diligence may apply (Article 13) after the operator checks supply-chain complexity and risks of circumvention or mixing, and confirms all relevant material comes from low-risk countries. Relevant risk information requires full assessment and mitigation.
- A due diligence statement in the Information System before the goods are placed or exported (Article 4(2)). Its reference number goes to customs before release (Article 26(4)).
- Pass the reference number on to the downstream operator or trader you sell to (Article 4(7)). You choose whether they can see the plots' geolocation (FAQ 7.7).
- Keep records for five years, tell the authorities and your customers about new risks (Article 4(5)), and review your due diligence system at least once a year.
Since 15 October 2026, each statement is assigned to the competent authority of the EU country where you are established (Implementing Regulation (EU) 2026/1565).
What should an importer do, and in what order?
- List your products and their customs codes. Check each against Annex I with a code lookup. Soluble coffee and new palm oil derivatives join on 30 December 2027.
- Confirm your date. 30 December 2026, unless you are a micro or small operator established as such by 31 December 2024 and your products aren't from the old EU Timber Regulation. Medium-sized companies, traders and downstream operators are in the first group. A delay checker shows which date applies.
- Register in the Information System. It runs on TRACES. The acceptance server is a copy for practice, with no legal value, and needs its own registration. The Commission runs free online training on statements on 3, 10, 17 and 24 November 2026.
- Send your suppliers a data request. For every lot: plot geolocation, production period, suppliers and land and legality documents. The guides for exporters and cooperatives explain the request from their side, so send them along.
- Decide how you will review plots. Who looks at each plot against imagery from before 31 December 2020, which forest maps you use, how you record a review status and what triggers a field check. The JRC 2020 forest map is a reference, not the legal baseline.
- Run one supplier end to end on the acceptance server: their plot file, your review, a draft statement. A statement prep sheet lists the fields in the order the system asks for them.
- File for real. One statement covers one activity: import, export or domestic. It can cover several shipments for up to a year if the quantities match (FAQ 5.19). You have 72 hours to amend or withdraw it, unless the goods have already been placed, a check has been announced or the number has gone to customs.
What changes for small and medium companies?
- Medium-sized companies (within two of these three limits: 250 staff, €50 million turnover, €25 million balance sheet; FAQ 3.10) follow the 30 December 2026 date like large ones.
- Micro and small operators established as such by 31 December 2024 have until 30 June 2027, except for products from the old EU Timber Regulation. Traders and downstream operators follow the December 2026 date whatever their size.
- Downstream SMEs and SME traders don't register in the Information System, but keep supplier and customer records for five years (Article 5).
What should you ask your suppliers for?
| Ask for | Why |
|---|---|
| A GeoJSON file of every plot behind each lot | The statement needs the geolocation of every plot (Annex II, item 3) |
| The production period for each lot | Required in your records (Article 9(1)(d)) |
| Land title, lease or certificate for each plot | Evidence of legal production |
| How lots are kept apart from untraced product | A lot mixed with product of unknown origin can't be covered |
| Who mapped the plots and when | Plots change; recent mapping is easier to trust |
Most suppliers outside the EU have no legal duty of their own, so the request is also a negotiation. Ask early, ask for one format, and accept a harvest season where exact dates don't exist.
Where to start
Settle your role and products this month, then send your largest supplier its data request. When their plots arrive, check them against what geolocation the EUDR requires. If your suppliers need somewhere to keep plots current between harvests, Restoration Scope for EUDR is built for their field teams.
Learn everything about the EUDR
From what the regulation asks to mapping plots, tracing lots and reviewing the evidence, in the order teams need it.
Understand the rule
- GuideWhat is the EUDR?
- GuideEUDR for EU importersYou’re reading this
- GuideEUDR for smallholder farmers
- Free toolEUDR scope checker
- Free toolEUDR HS code and country lookup
Frequently asked questions
Is an EU importer an operator under the EUDR?
Usually yes. The operator is the company that first places a relevant product on the EU market or exports it. For imported coffee, cocoa or wood that is normally the company that releases the goods for free circulation, which files the due diligence statement.
What is the difference between an EUDR operator and a trader?
The operator first places the product on the EU market and files the due diligence statement. A trader sells products that are already on the market, such as a wholesaler or retailer, files nothing and keeps supplier and customer records. A company that turns covered products into a product with a different customs code, such as a chocolate maker, is a downstream operator.
When does the EUDR apply to importers?
The rules apply from 30 December 2026. Qualifying micro and small operators established as such by 31 December 2024 have until 30 June 2027, except for products from the old EU Timber Regulation. Traders and downstream operators follow the December 2026 date. Medium-sized companies are in the December 2026 group.
Do roasters and chocolate makers still file due diligence statements?
No, if they buy from an EU importer. Since Regulation (EU) 2025/2650, downstream operators and traders file no statement. The first one after the operator keeps the statement's reference number, and those above SME size register in the EU Information System.
Can one due diligence statement cover several shipments?
Yes. The Commission's FAQ allows one statement for several shipments, as long as it covers no more than one year from submission and the quantities match what is placed on the market.
Another question? Email us or book a call.
