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Written by
May 6, 2025
min read

## EUDR Reporting Guide for Traders

### Introduction

The EU Deforestation Regulation (EUDR) is a new law requiring companies to ensure that products placed on or exported from the EU market are deforestation-free. While most guidance focuses on operators, traders also have specific obligations—often underestimated but critical for compliance. With the regulation taking full effect in 2025, traders must act now to avoid future disruptions.

This guide breaks down EUDR reporting requirements specifically for traders. You’ll learn who qualifies as a trader, what data needs to be collected, and how to prepare for audits. Whether you're an SME or a large distributor, this article will help you build a scalable and compliant reporting process.

### Who is considered a trader under EUDR?

#### Definition of traders

Traders under EUDR are companies that make relevant products available on the EU market without altering them. Unlike operators—who place products on the market for the first time—traders are further downstream in the supply chain but still have legal responsibilities.

#### Examples of trader activities

* A timber wholesaler reselling imported planks to furniture makers
* A coffee distributor buying roasted beans from an EU importer and supplying cafes
* A commodity broker trading soy oil already placed on the market by another business

📎 PAA keyword: Who is considered a trader under EUDR?

### What are the reporting obligations for traders?

#### Key compliance tasks

Traders must:

* **Retain documentation**: Keep upstream due diligence statements (DDS) and related documents
* **Pass on data**: Ensure downstream clients have access to the compliance information
* **Support traceability**: Maintain records of origin and supplier details

#### SME vs. non-SME obligations

* **SME traders**: Must store and share compliance data, but aren’t required to conduct full due diligence
* **Non-SME traders**: Must perform risk assessments and submit their own DDS, similar to operators

📎 PAA keyword: What are the reporting obligations for traders under EUDR?

### Step-by-step reporting process for traders

#### Step 1: Identify your role and obligations

Check whether your business qualifies as a trader or operator. Clarify whether you fall under the SME threshold, as it affects your compliance duties.

#### Step 2: Collect and organize necessary data

You’ll need to track:

* Supplier names and locations
* HS codes and product descriptions
* Dates and countries of production
* Any received DDS and supporting evidence

#### Step 3: Maintain traceability

Implement tools that allow you to track goods across your supply chain. A digital traceability system simplifies recordkeeping and audit preparation.

#### Step 4: Prepare for audits

Auditors may request your data at any time. Assign a compliance officer, set internal check-ins, and ensure data is retrievable and accurate.

### Common mistakes traders make and how to avoid them

#### Mistake #1: Assuming traders have no obligations

Even if you're not placing products on the market first, you're still legally accountable under EUDR.

#### Mistake #2: Poor documentation practices

Not organizing or backing up data can result in non-compliance. Use centralized digital tools.

#### Mistake #3: Misclassifying your company size

Regularly check your SME status. If you grow beyond the threshold, your obligations change.

Note: This article is based on the original CSRD and ESRS. Following the release of the Omnibus proposal on February 26, some information may no longer be accurate. We are currently reviewing and updating this article to reflect the latest regulatory developments. In the meantime, we recommend reading our Omnibus deep-dive for up-to-date insights on reporting requirements.

Read the Omnibus article here

Updated on March 24, 2025 - This article reflects the latest EU Omnibus regulatory changes and is accurate as of March 24, 2025. Its content has been reviewed to provide the most up-to-date guidance on ESG reporting in Europe.

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