Under the EUDR, operators are all companies that place regulated products on the EU market or export them outside the EU. This includes importers, EU manufacturers, and exporters.
Following the Parliament’s 26 November 2025 vote, two additional subcategories have been adopted: downstream operators and small and micro primary operators, each with simplified or exempted due diligence obligations depending on their role and risk profile.
Important note:
These new roles and exemptions are not yet law. They will only apply once the final legal text is adopted and published in the Official Journal of the EU.
