ERWAY
All glossary terms
Roles & obligations

Downstream operator

Places on the market a product already covered by upstream diligence — retains the reference number, registers if not an SME, and must act if aware of a substantiated concern.

What it means

A downstream operator places on the market a product that already contains, or was made from, goods on which due diligence was already done. After the 2025 amendment, that role does not refile a statement for the same goods.

In the regulation

The duty is to collect and keep the upstream reference number and to be able to produce it. Downstream operators that are not SMEs must register in the Information System. Good-faith reliance on an upstream operator ends if you become aware of a substantiated concern — you must act rather than pass the goods on regardless.

How ERWAY treats it

ERWAY’s downstream workflows emphasise statement intake, reference validation and shareable process packs — not a second full geolocation campaign for plots already filed upstream.

See what this looks like on your own supplier data

ERWAY turns supplier plot geometry into deforestation risk intelligence and a submission-ready EU Due Diligence Statement. Take the two-minute interactive tour.