Operator | EUDR glossary
Who counts as an operator under the EUDR after the 2025 amendment, and why operators are the ones who submit geolocation.
‘operator’ means any natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them, excluding downstream operators
The operator is the first to place a relevant product on the EU market: usually the importer, or the one who exports it. Operators carry the due diligence duty and submit the due diligence statement, geolocation included.
Since the 2025 amendment (Regulation (EU) 2025/2650, Art. 1(1)), the definition excludes downstream operators: companies that make or sell products from inputs already covered by a statement. Before it, many of them were operators too.
A company established outside the EU cannot be the operator for its own shipments in this sense: the first person established in the Union who makes the products available is deemed to be the operator (Regulation (EU) 2023/1115, Art. 7).
For geolocation, this means the operator is the one who has to collect the plots from suppliers and get the file right.
Sources
- Regulation (EU) 2023/1115 (the EU Deforestation Regulation), Art. 2(15), Official Journal of the European Union, L 150, 9.6.2023
- Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115, Art. 1(1), Official Journal of the European Union, 23.12.2025
- Regulation (EU) 2023/1115 (the EU Deforestation Regulation), Art. 2(16), Official Journal of the European Union, L 150, 9.6.2023
- Regulation (EU) 2023/1115 (the EU Deforestation Regulation), Art. 7, Official Journal of the European Union, L 150, 9.6.2023
Last verified against these sources on .