ERWAY
All glossary terms
Roles & obligations

Operator

Also known as: Primary 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.

What it means

After Regulation (EU) 2025/2650, the statement is filed once, by whoever first places the goods on the EU market (or exports them). That party is the primary operator for those goods — usually the importer, sometimes an EU producer.

Roles attach to products, not to company names: the same business can be operator for one flow and trader for another.

In the regulation

The operator collects the Article 9 information (including geolocation), runs assessment and mitigation as required by the risk tier, maintains an Article 12 system, and submits the Due Diligence Statement through the Information System before placing or exporting.

How ERWAY treats it

ERWAY treats the filing operator as the account that owns plot geometry, supplier evidence and the DDS submission path. Role selection in onboarding decides which modules light up.

Related 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.

  • 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.

  • 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

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.

See how the system worksBook a demo