Under EUDR, are you an operator or a trader?

It’s the first question the regulation asks of you, and it decides how much work lands on your desk. The two roles carry very different duties, and most small coffee and cocoa importers are surprised to learn which one they are.

The EU Deforestation Regulation (Regulation (EU) 2023/1115) splits the people who handle in-scope goods into two roles: operators and traders. The label matters because nearly all of the real obligation (the due diligence, the plot geolocation, and the Due Diligence Statement filed in TRACES) sits with the operator. A smaller trader further down the chain mostly records and passes along reference numbers.

If you are an EU business that buys coffee or cocoa from outside the EU and brings it in, this page is written for you. In almost every case, that act makes you the operator.

The distinction

Who first places the product on the EU market?

EUDR turns on one idea: placing on the market. The operator is the party that first makes an in-scope product available on the EU market in the course of business: for imported goods, that is typically the EU importer bringing the coffee or cocoa across the border. The operator must exercise due diligence and submit a DDS before the product is placed on the market.

A trader is someone further along the chain who makes the product available to others, a wholesaler or distributor buying already-imported beans from an EU operator. A small or micro trader has the lighter duty: chiefly collecting, keeping, and passing on the DDS reference numbers of the goods it handles, so the chain stays traceable. A larger trader, though, carries due-diligence obligations much like an operator’s. Either way, for imported coffee and cocoa the geolocation and the deforestation assessment are done upstream by the operator who first places the goods on the market, and that is who this page is for.

An honest self-check

Which one are you?

Answer three quick questions. It won’t hand you a false verdict: where the role genuinely turns on the details of your supply chain, it says so and points you to a conversation rather than a dead end. A plain guide, not legal advice.

This quick self-check needs JavaScript. The two lists just below cover exactly the same ground. Read those instead.

Or read it through

The two roles, side by side.

You are likely an OPERATOR if…

You import coffee or cocoa from outside the EU and are the first EU business to place it on the market.
You buy green beans directly from a producer, cooperative, or exporter abroad and clear them into the EU yourself (or via your customs representative).
You’re the party whose name and EORI sit on the import: the goods become “available on the EU market” because of you.
You would be the one an authority turns to for the geolocation of the plots your beans came from.

If these describe you, the due-diligence duty and the DDS are yours. You must gather the plot geolocation, satisfy yourself the product is deforestation-free against the 31 December 2020 cut-off, and file the statement in TRACES.

You are likely a TRADER if…

You buy coffee or cocoa that has already been imported and placed on the EU market by someone else.
Your supplier is an EU operator who already filed a DDS and can give you its reference number.
You resell or distribute within the EU without being the first to bring the goods across the border.
Your main EUDR job is to record and pass on the DDS reference numbers of what you handle, keeping the chain traceable.

If these describe you, you generally rely on the operator’s statement rather than producing your own. (Note: a small or micro trader can fall into a different bracket. If you’re unsure, it’s worth checking.)

Common cases

A few situations that trip people up

“I’m a small roaster who imports my own green coffee.”

You’re the operator. Buying green beans abroad and bringing them into the EU is placing them on the market: the DDS is yours to file, even at small volumes.

“I buy already-imported beans from an EU wholesaler.”

You’re acting as a trader on that purchase. Ask your supplier for the DDS reference number and keep it: you’re relying on the operator’s due diligence, not repeating it.

“I do both: I import some lots and buy others locally.”

Then you’re an operator for the lots you import and a trader for the ones you buy already-placed. The role is decided per consignment, by whether you were first to place it on the EU market.

“Doesn’t the 2025 simplification let me skip geolocation?”

No, not for you. The one-time “simplified declaration” (a postal address instead of plot geolocation) is for small or micro primary operators placing produce they grew themselves, in low-risk countries. An EU importer of someone else’s coffee or cocoa is not a primary operator, so you still file a full DDS with plot geolocation, whatever the origin country’s risk class.

When you actually have to do this

The timing depends on your size. As it currently stands, large and medium operators and traders come into scope from 30 December 2026, and micro and small enterprises from 30 June 2027. Most direct-import coffee and cocoa roasters and buyers fall into that second group, so 30 June 2027 is the date to plan around. These deadlines have moved before, so treat them as the current position rather than a fixed promise, but the direction of travel is clear, and the geolocation and record work is easier to get in order early than in a rush. See the EUDR deadlines, kept current for the dates as they stand today.

One thing that doesn’t change with size: the legal responsibility for the declaration stays with you, the operator. A service can do the assessment and file on your behalf, but the duty and the liability remain yours. That’s exactly why the work behind the statement should be documented and defensible, so if you’re ever asked, the reasoning is already written down. EUDR also expects you to keep those due-diligence records for five years.

If you’re the operator

We do the filing work, so you don’t carry it alone.

If you import your own coffee or cocoa, the DDS is yours to file, and we can do the assessment and the TRACES submission for you, as your Authorised Representative. Tell us what you import and where from, and we’ll show you what your filing would involve.

contact@glebora.com

Not sure which role you’re in? Send us your setup and we’ll help you place it.