An operator is the actor who places a relevant product on the EU market for the first time or exports it, excluding downstream operators. Operators carry the full due diligence obligation under the EU Deforestation Regulation.
Whoever brings a product into the EU – or sends it out – sits at the point where the entire due diligence process must be completed.
What are an operator's obligations?
- Collect data, including the geolocation coordinates of the plots of production
- Carry out a risk assessment of the deforestation risk
- Apply risk mitigation where needed, aiming for negligible risk
- Submit a due diligence statement via TRACES NT
- Retain all records for five years
Operator or trader?
The difference is decisive. A trader only passes products that are already on the market further down the chain, with lighter obligations. An operator places products on the market for the first time and therefore carries the full obligation. Typical operators include an importer, a forest owner selling directly, or a business (such as a sawmill) that imports timber itself.
Timeline: For timber the obligations apply from 30 December 2026 regardless of company size (Art. 38(3)); the extended deadline of 30 June 2027 – only for natural persons, micro and small undertakings established as such on 31 December 2024 – only covers newly included products.