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.
Related terms
- Roles & obligations
Operator
The person who first places a relevant product on the EU market, or exports it — and who files the Due Diligence Statement for that placing.
- Roles & obligations
Trader
Makes a relevant product available without first placing it — retains the reference number; non-SME traders must register in the Information System.
- Risk & benchmarkingHigh risk (country)
Substantiated concern
A duly reasoned claim based on objective, verifiable information — it reopens full due diligence for affected goods and can end Article 13 simplification.
- Filing & enforcement
Due Diligence Statement
The filing by which the first-placing operator formally declares that due diligence was carried out and that risk is negligible — required at every country risk tier.
Keep reading
Roles & obligationsOperator, downstream operator, trader: who files what
How EUDR roles work after Regulation (EU) 2025/2650: who submits a due diligence statement, who retains reference numbers, and who registers without filing.
6 min read
Filing & enforcementThe Due Diligence Statement and the EU Information System, end to end
What goes into an EUDR due diligence statement, how it reaches the EU Information System, what the reference number is for, and what the 2026 rebuild changed.
6 min read