Trader
Makes a relevant product available without first placing it — retains the reference number; non-SME traders must register in the Information System.
What it means
A trader makes a relevant product available on the market in commercial activity without being the operator who first placed it. Like downstream operators, traders carry the upstream reference rather than filing again.
In the regulation
Traders collect and retain due-diligence information, including reference numbers, and make it available to competent authorities on request. Traders that are not SMEs must register in the Information System. They remain inside the Article 25 penalty envelope alongside operators.
How ERWAY treats it
Trader accounts in ERWAY focus on retention and shareable evidence without a DDS filing workflow that only the first-placing operator needs.
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
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
SME
EU size class that changes application dates — with a timber trap: micro and small operators already under the old EUTR follow December 2026, not the later SME date.
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 & enforcementPenalties under Article 25: what non-compliance actually costs
The EUDR penalty regime: fines of at least 4% of EU turnover, confiscation of products and revenues, procurement exclusion, market bans, and the criminal liability layer.
5 min read