The EU Deforestation Regulation (EUDR) requires that products covered under the EUDR placed on or exported from the EU market are deforestation-free and legally produced. Following a targeted revision, Regulation (EU) 2025/2650 was formally adopted in December 2025, postponing and simplifying the regulation. The new enforcement dates are 30 December 2026 for large and medium operators and traders, and 30 June 2027 for micro and small enterprises.

Traders play a crucial role in this system, bearing the responsibility to maintain and pass on traceability information across the supply chain. Their role is even more critical given how fragmented commodity markets are, often involving multiple layers of intermediaries before products reach the end market. In this guide, we break down what EUDR means for traders under the amended regulation and outline practical steps - from identifying your role to preparing for audits - to help you meet the requirements. For a broader overview, see our EUDR timeline tracker.

Who is considered a trader under EUDR?

Traders vs operators vs downstream operators

Under the amended EUDR, a trader is defined as any natural or legal person who, in the course of a commercial activity, makes regulated products available on the EU market. In practice, this includes distributors, wholesalers and retailers who buy and resell EUDR-covered commodities within the EU after they have already been placed on the market by an operator.

This is distinct from an operator, who is the entity that first places the product on the EU market or exports it. For a detailed breakdown of operator obligations, see our reporting guide for operators.

Regulation 2025/2650 also introduced a new category: the downstream operator. A downstream operator is someone who places on the market or exports products that are already covered by an existing due diligence statement (DDS) or simplified declaration. Many businesses previously classified as traders may now fall into this category, depending on their position in the supply chain.

What are the responsibilities of traders under the amended EUDR?

The December 2025 amendments significantly simplified the obligations for traders and downstream operators. The key change: traders no longer need to submit their own DDS. Only the operator who first places the product on the EU market is required to file a DDS. Here is what traders must do:

1. Collect and retain DDS reference numbers: Traders must obtain the reference number of the upstream DDS from their supplier and retain it for at least five years. This is the core traceability obligation - ensuring an unbroken chain of documentation from the first operator to the end market.
2. Register in TRACES: Non-SME traders and downstream operators must register in the EU's Information System (TRACES), although they do not need to file DDS returns.
3. Maintain traceability records: Traders must keep records of the name and address of suppliers and customers, as well as the DDS reference numbers associated with each transaction. This information must be made available to authorities upon request.
4. Report suspected non-compliance: If a trader suspects that a product is linked to deforestation or illegal activity, they must report it to the relevant national competent authority.
5. Cooperate with authorities: Traders must cooperate with competent authorities during checks and provide all requested documentation. For more on how enforcement and monitoring works, see our dedicated guide.

For micro and small enterprises sourcing from low-risk countries, the amended regulation introduces a simplified declaration (new Annex III) as an alternative to a full DDS. This significantly reduces the compliance burden for smaller traders in lower-risk supply chains.

For a full breakdown of due diligence requirements under the EUDR, including what operators must prove, see our detailed explainer.

Country risk benchmarking: what traders need to know

In May 2025, the European Commission published its first country risk classifications under the EUDR. The benchmarking system categorizes countries into three tiers:

• High risk (4 countries): Belarus, Myanmar, North Korea and Russia
• Standard risk: Most major commodity-producing countries, including Brazil, Indonesia and several African nations
• Low risk (140 countries): All EU Member States, the US, Canada, China, Ukraine, Thailand and others

For traders, the risk classification of the source country directly affects the level of due diligence expected from operators upstream - and by extension, the reliability of the DDS reference numbers you receive. If your supply chain involves standard or high-risk countries, extra scrutiny on supplier documentation and risk assessment is warranted. A revision of these benchmarks is expected in 2026 when updated FAO deforestation data becomes available.

How should traders prepare for EUDR compliance?

With enforcement starting 30 December 2026 (or 30 June 2027 for micro and small enterprises), traders should take the following steps now:

1. Clarify your role: Determine whether you are a trader, downstream operator or operator under the amended EUDR. Your obligations differ significantly depending on your position in the supply chain. If you are an SME, consult our SME-specific EUDR guide for tailored guidance.
2. Map your supply chain: Identify all suppliers and understand the origin of your products. Create a comprehensive supply chain map that details where commodities are sourced and how they are processed. For practical steps, see how to integrate EUDR into your procurement process.
3. Set up DDS reference number collection: Establish a system to request, receive and store DDS reference numbers from your suppliers. This is your primary compliance obligation. Work with suppliers to ensure they can provide these references - see our guide on how to collect EUDR data from your suppliers.
4. Register in TRACES: If you are a non-SME trader, register in the EU Information System. Note that the system was temporarily taken offline in February 2026 for updates aligned with Regulation 2025/2650 and is expected to be available again by mid-2026.
5. Train your team: Ensure that employees understand the amended EUDR requirements and their role in compliance. Focus training on the new DDS reference number workflow and the distinction between trader and operator obligations.
6. Prepare for checks: While enforcement has not yet begun, the first compliance checks are expected from 30 June 2026 at the earliest. Establish internal review procedures to regularly verify your documentation is complete and up to date. For a complete compliance roadmap, see our step-by-step EUDR compliance guide.

An April 2026 Simplification Package from the European Commission is also expected, which may include revised FAQs, updated guidance and amendments to the implementing regulation. Traders should monitor these developments closely.

By taking these proactive steps, traders can ensure they are well-prepared to meet the EUDR requirements and avoid potential penalties for non-compliance.