‘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

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