EUDR for Downstream Operators: What You Actually Need to Do in 2025

A lot of EUDR information out there focuses on importers’ obligations. But what if you’re not the first company bringing commodities into the EU?

Let’s say you roast coffee, blend cocoa, manufacture furniture, or distribute packaged food - are you then free of the EUDR compliance burden?

Not so quick!

Many downstream are still considered “operators” under the EUDR. They will therefore also face due diligence obligations. Here’s what that means, and how you can handle it.

Quick definitions for clarity

• Operator: Any company placing EUDR-regulated commodities or products on the EU market.
• Trader: Companies only making products available on the market. Many still count as operators.
• Downstream operator: Manufacturers, processors, or distributors who use commodities (coffee, soy, cocoa, palm, timber, cattle, rubber) and then sell onward.

The Commission’s guidance makes it clear: even if you didn’t import the beans, logs, or oil, you may still need to submit a due diligence statement (DDS).

What does “downstream operator” mean in practice?

Think of EU companies that are:

• Coffee roasters importing green beans from a trader, but selling roasted beans in the EU.
• Furniture assemblers buying certified timber from a wholesaler, but placing finished products on the market.
• Tire companies turning rubber into finished tires and selling them.
• Soy milk or chocolate brands sourcing beans from an importer and blending them into finished goods.

All of these become “second operators.”

Once you transform or repackage an imported commodity covered by EUDR, it is considered as placed on the market again. In this case, you need to perform full due diligence as well. For further information and to confirm if your commodities need to undergo due diligence in this context, consult EUDR Annex I (page 38 and following).

Your obligations by size

The regulation distinguishes:

• Large enterprises that must run full due diligence, every time.
• Small and medium-sized enterprises (SMEs) that may use simplified procedures, mainly relying on upstream DDSs.

“Simplified” does not mean “exempt” though.

Even small companies must:

• Capture and reference upstream DDSs.
• Store Reference Numbers / Validation Numbers.
• Provide these on request to authorities.

Who counts as an SME?

Businesses that fulfill 2 out of the following 3 criteria:

• average number of employees up to 250
• net turnover of less than EUR 50,000,000
• balance sheet of less than total EUR 25,000,000

If your upstream DDS is incomplete, you may still be liable.

Submitting a DDS the right way

EUDR compliance happens inside the EU’s online platform TRACES NT. Downstream operators can:

Reference upstream DDSs by entering their Reference Number / Validation Number.

Validate that those numbers are active and linked to the right commodity.

File their own DDS when no valid upstream DDS exists. This applies when a change to the commodity occurs, for instance, by blending cocoa beans.

So do not assume upstream paperwork covers you automatically. Referencing may suffice in some cases, but you have to have a system to confirm validity and keep records.

Competent authorities want to see that you are doing due diligence across your supply chain, not just ticking boxes.

Geolocation and files you’ll be asked for

Even downstream operators need to understand the basics:

• Plot-level data → GPS coordinates of the farm or forest origin.
• Formats regulators expect → GeoJSON, CSV, KML.
• Associated docs → supplier declarations, sourcing contracts.

If you’re referencing upstream DDSs, these files are usually attached. If you’re creating your own, make sure your tools can export in the right formats.

But wait - there are tools to help you!

You may have guessed it. Or maybe you hoped for it. There is software out there that takes the pain out of compliance. Even for downstream operators.

Here is how the best tools alleviate your concerns and accelerate your compliance journey:

• Bulk DDS creation → generate DDSs from your input data, even for blends.
• RN/VN validation → check supplier DDSs automatically, without manual lookup.
• Supplier onboarding → invite suppliers into a portal with guided forms and reminders.
• Audit-ready records → everything stored in one place, ready for inspections.

Orbify was built for exactly this. Whether you’re a roaster, brand, or distributor, our platform handles referencing, DDS creation, and TracesNT submission without extra consultants or IT projects.

The downstream operator pitfall: a case study

A young coffee brand buys coffee beans from a trusted importer. They assume the importer’s DDS covers them until an inspection request lands.

The problem: once they roasted the coffee beans and placed the finished coffee powder on the market, the importer’s DDS no longer applied. The brand needed its own DDS, referencing the upstream data. Now they need to assemble records quickly and are risking penalties.

Lesson learned: the law expects each operator to keep its own due diligence records.

With Orbify, the brand could have referenced the upstream RN/VN, validated it, and generated a downstream DDS. Within minutes and without last-minute panic.

Act now and get compliant within a day

Downstream operators are not automatically exempt from EUDR compliance and due diligence. But the good news is that the right tools exist to make your compliance journey quick, affordable, and painless - for small and large companies alike, and even if you are a downstream operator.

Book a demo to see how Orbify simplifies EUDR for downstream manufacturers and brands.