A micro or small primary operator is a natural person or micro/small enterprise established in a country classified as low‑risk under Article 29 that places relevant products on the EU market or exports them, provided they produced these products themselves. This means they grow, harvest, obtain, or raise the relevant commodities directly.
Following the European Parliament vote on 26 November 2025, micro and small primary operators will no longer be required to submit full due diligence statements (DDS).
Instead, they must:
- Submit a one-time simplified declaration,
- Update it only if major operational changes occur,
- May use postal addresses instead of geolocation, and
- May be exempt from submitting anything if equivalent data exists in a national database.
This simplification reduces compliance burdens while preserving supply chain traceability. However, it is not yet law and will only apply once formally adopted and published in the EU Official Journal.
