EUDR: Important clarifications on downstream operators
- Feb 10
- 2 min read
On 10 February 2026, CEI-Bois & EOS participated in the Deforestation Platform meeting. In this occasion, it was explained that as provided for in Regulation (EU) 2025/2650, the obligation to collect and retain reference numbers applies exclusively to the first downstream operator or trader placing products on the market. This obligation does not extend to operators or traders further down the supply chain. This implies and it has been confirmed that downstream operators cannot submit DDS.
Their access to the Information System will be limited to verifying whether due diligence has been exercised in line with Articles 5(6) and 5(7), and only in a scenario of substantiated concerns.
The Commission also stressed that any downstream operators requesting DDS from any downstream operators in the value chain, would go against the spirit of the simplification. Moreover, as the first downstream operators cannot submit DDS themselves, not even the first downstream operators will be technically in the position to provide these DDS and so, their downstream clients.
The Commission also addressed the possibility of bundling/grouping the reference numbers of existing DDS. Pending approval, the approach proposed by the Commission will be that, since only upstream operators would be able to submit DDS, only upstream operators will be able to also group them. Moreover, they will only be able to reference those DDS that they themselves have submitted.
A consolidated version of the EUDR is now available here:
Please note that this document has been prepared by the European Commission as a documentation tool, combining the first EUDR text (REGULATION (EU) 2023/1115) with the amendments adopted in December (REGULATION (EU) 2025/2650). This document has no legal effect. The only authentic versions remain the separate acts as published in the Official Journal of the European Union.
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