Downstream operator | EUDR glossary

The downstream operator category added to the EUDR in 2025: who it covers and what it means for passing on geolocation and reference numbers.

‘downstream operator’ means any natural or legal person who, in the course of a commercial activity, places on the market or exports relevant products made using relevant products, all of which are covered by a due diligence statement or by a simplified declaration

A downstream operator transforms or sells on products whose inputs were already covered by someone else's statement: a chocolate maker using cocoa imported under an importer's statement, for example.

Downstream operators do not submit their own due diligence statements. They must hold the information set out in the new Article 5: who supplied them and who they supplied, and, where the supplier is an operator, the reference numbers of the statements covering the products (Regulation (EU) 2025/2650, Art. 1(6)). Larger ones register in the Information System.

For geolocation, a downstream operator typically never sees the plot file. They see a reference number that points to it.

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