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 small and micro operators (non-timber products).

This guide covers what the EUDR means for traders specifically: how the role is defined, what due diligence obligations apply, and what you need to do to be ready before the application date.

Who is a trader under the EUDR?

A trader is any person in the supply chain other than an operator or downstream operator who makes relevant products available on the market in the course of a commercial activity (Article 2(17), Regulation (EU) 2023/1115). Traders do not place products on the market for the first time, and they do not transform relevant products — they buy and resell products that have already been placed on the EU market.

The distinction matters because traders carry fewer obligations than operators. They are not required to conduct due diligence, submit a Due Diligence Statement (DDS), or verify that due diligence was exercised upstream.

What do traders need to do?

Under the revised EUDR (Regulation (EU) 2025/2650), traders are required to:

• Collect and keep information about their direct suppliers and commercial clients, including name, postal address, and email address
• If their direct supplier is an upstream operator, also collect and keep the DDS reference numbers or declaration identifiers associated with the products
• Register in the EUDR Information System if they are a non-SME
• Inform competent authorities immediately if they become aware of information indicating non-compliance, including substantiated concerns

Traders who purchase from other downstream operators or traders — rather than directly from an upstream operator — are not required to collect DDS reference numbers. Their obligation is limited to basic business partner information.

What traders do NOT need to do

Traders are not required to:

• Conduct due diligence or risk assessment
• Submit a DDS to the EUDR Information System
• Verify that due diligence was carried out upstream
• Proactively investigate their supply chain for compliance evidence

This significantly reduces the compliance burden compared to operators. The obligations that do apply are largely administrative and data-retention focused.

Non-SME trader obligations

Non-SME traders (i.e. medium and large enterprises) have one additional obligation beyond smaller traders: if they become aware of substantiated concerns about non-compliance, they must verify that due diligence was exercised and that no or only negligible risk was found before continuing to make products available on the market (Article 5(6), Regulation (EU) 2023/1115).

This is a reactive obligation — it only applies when a concern is raised. It does not require ongoing monitoring or proactive supply chain investigation.

Penalties for non-compliance

Traders who fail to comply with the EUDR can face the same penalties as other operators: fines of up to at least 4% of annual EU turnover, confiscation of goods, and potential suspension from placing products on the market. Even traders with lighter obligations should ensure their information collection and retention processes are in order before the application date.

For a full breakdown of enforcement and penalty mechanisms, see Coolset's EUDR compliance and enforcement guide.

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How Coolset helps traders

Coolset's EUDR solution supports the full due diligence workflow, from supplier data collection to DDS submission. Traders using Coolset can track reference numbers from upstream operators, maintain the required audit trail, and stay ready for any compliance checks ahead of the December 2026 application date.

See Coolset's EUDR module in action. Request a demo today.

June 2026 update: Simplification package confirmed

The April 2026 Simplification Package referenced in this article was published on 4 May 2026 (COM(2026) 191 final), along with an updated Guidance Document (3rd edition) and new FAQs. The key clarifications most relevant to traders are now confirmed.

The Guidance Document (3rd edition) confirms that the obligation of the first downstream operator or trader to collect reference numbers is passive. Traders are not required to investigate or proactively ask suppliers for reference numbers. Acting in good faith, a trader may presume their supplier is not an upstream operator if no reference numbers are received from them. This removes any expectation of active supply chain investigation for traders further down the chain.

On the question of compliance costs: the Commission estimates that, combined, the simplification measures introduced since 2024 reduce annual compliance costs for companies subject to EUDR obligations by approximately 75% — from EUR 8.1 billion to EUR 2.0 billion per year (COM(2026) 191 final, Chapter 5). The largest driver of cost reduction for traders specifically is the shift to passive reference number collection and the removal of the obligation to ascertain that due diligence was exercised upstream.

FAQ — EUDR for traders

1. Does the EUDR apply to traders?

Yes. Traders are subject to the EUDR if they make relevant products available on the EU market in the course of a commercial activity. However, their obligations are significantly lighter than those of operators: no due diligence, no DDS submission, and no obligation to verify compliance upstream.

2. What is the difference between a trader and an operator under the EUDR?

An operator is the first person to place a relevant product on the EU market or export it. They must conduct full due diligence and submit a DDS. A trader buys and resells products already on the market — they are not required to perform due diligence or submit a DDS, but must keep traceability records.

3. When does the EUDR apply to traders?

Under Regulation (EU) 2025/2650, trader obligations apply from 30 December 2026 for medium and large traders, and from 30 June 2027 for small and micro traders (non-timber products).

4. What records do traders need to keep?

Traders must retain information about their direct suppliers and clients (name, address, email). If their direct supplier is an upstream operator, they must also retain the DDS reference numbers for at least five years and make them available to competent authorities on request.