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
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
Regulation & scopeEUDR in plain terms: what Regulation (EU) 2023/1115 actually requires
The EUDR's scope, the three conditions every product must meet, the 31 December 2020 cut-off, and what due diligence actually consists of.
6 min read
