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EUDR for small businesses, downstream operators and traders

The 2025 amendments lightened EUDR obligations for some actors. Here is what micro and small producers, downstream operators and traders must do.

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Answers are written by a language model solely from this base's documents, with numbered sources. They can be wrong and aren't legal, medical or financial advice: check the sources before any important decision.

The one-time simplified declaration

A 'micro or small primary operator' is a natural person or a micro or small undertaking established in a low-risk country that sells or exports products it has itself grown, harvested or raised there.

Instead of a due diligence statement per shipment, it submits a one-time simplified declaration (name, address, EORI number where relevant, HS code, product description and estimated annual quantity) and receives a declaration identifier, needed before selling. The postal address of the plots may replace geolocation, and no declaration is needed if this information is already in an existing EU or national database.

Downstream operators and traders

A downstream operator sells or exports products made from relevant products already covered by a due diligence statement or simplified declaration; a trader is anyone else making them available on the market.

Both keep for at least five years the name, address and email of suppliers and customers, plus the statement reference numbers or declaration identifiers when the supplier is an operator. Non-SME downstream operators and traders must also register in the information system.

Frequently asked questions

Can a small supplier ask a customer to file for it?

Yes. An operator that is a natural person or a microenterprise may mandate the next downstream operator or trader that is not a natural person or microenterprise to act as its authorised representative. The operator remains responsible for compliance.

What must an operator pass on to the next company in the chain?

The reference numbers of their due diligence statements, or the declaration identifiers where a simplified declaration was used.

What should a trader do if it learns that a product may not comply?

It must immediately inform the competent authorities of the Member States concerned and the downstream operators and traders it supplied.

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{
  "mcpServers": {
    "kopik-eu-eudr-deforestation": {
      "url": "https://kopik.io/api/mcp?base=eu-eudr-deforestation",
      "headers": {
        "Authorization": "Bearer kpk_…"
      }
    }
  }
}

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