The European Commission released a new EUDR proposal in October 2025, clarifying expectations for operators further down the supply chain. Under this proposal, downstream operators would no longer submit due diligence statements. However, traceability remains non-negotiable.
Under this proposal, instead of submitting due diligence statements, downstream operators, such as manufacturers purchasing processed goods, must:
→ Record the reference number from the upstream operator’s due diligence statement
→ Pass this reference number along to the next actor in the supply chain
What stays the same?
The obligation to maintain full traceability. Here’s a practical example: A chocolate manufacturer buying processed cocoa butter from an EU-based importer is considered a downstream operator. They don’t file their own due diligence. But they must log and pass on the importer’s reference number to maintain the traceability chain.
Why does this matter?
EUDR compliance depends on a complete, verifiable audit trail, from the original producer to the final market entry. If even one link is missing, the entire chain is considered non-compliant.
