A trader is any actor in the supply chain – other than the operator – who makes a relevant product available on the market without changing its nature. In other words: a product that has already been placed on the market is passed on further.
The trader's obligations are lighter than those of an operator, because the product has already been through the due diligence process when it was first placed on the market.
What are a trader's obligations?
- Collect and keep the reference numbers of the due diligence statements from suppliers
- Pass these reference numbers on to customers
- Ensure traceability along the supply chain
- Retain the relevant records for five years
Trader or operator?
An operator places a relevant product on the EU market for the first time and carries the full due diligence obligation. Exporting alone does not make you an operator: whoever exports goods already covered by a declaration is a downstream operator (Art. 2(15b)). A trader only passes products on. If you change a product's nature or import it, you act as an operator – with the corresponding obligations.
Important: Traders that are not SMEs (large traders) have extended obligations: since the 2025 amendment they must register in TRACES NT, collect and pass on their suppliers' reference numbers, and check – where there is substantiated concern – whether due diligence was carried out. Unlike an operator, they do not file a due diligence statement of their own. Smaller traders (SMEs) mainly have to record and pass on reference numbers.