The EUDR Role-Mapping Playbook for Real-World Trade Flows

Liudmila Chambers

Associate Director

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Liudmila Chambers

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Tim Mollenhauer

Principal Consultant

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Tim Mollenhauer

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Table of Contents

• The importance of mapping trade flows
• The role of the downstream operator
• Determining products in scope
• The EUDR is about more than importing and exporting
• Not every company needs a digital EUDR solution
• Looking ahead

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As businesses continue preparing for the EU Deforestation Regulation (EUDR), one question consistently generates confusion:

What is my role under the regulation?

While much of the EUDR conversation has focused on geolocation data, due diligence statements (DDS), and supply chain traceability, many organisations are still unsure whether they are acting as an upstream operator, downstream operator, trader, or whether their products are even in scope at all.

This uncertainty is understandable. EUDR obligations are not determined solely by whether a company imports or exports products to and from the European Union (EU) and whether they contain any of the in-scope commodities.

In practice, a company’s role under the EUDR depends on:

• Whether their products’ HS codes are included in Annex I of the EUDR
• Whether their products are being placed on the EU market for the first time
• How their products move through the supply chain

With deadlines approaching, we’re receiving numerous questions on role classification and responsibility allocation. These questions highlight a common challenge: organisations often understand the basics of the regulation but struggle to apply it to their specific trade flows.

Below, we outline recommendations for mapping EUDR scope and exposure to real-world trade flows, and how to better understand your role and responsibilities.

The importance of mapping your trade flows

Our experience working with companies to understand their EUDR exposure suggests that the same company could act as an upstream operator for some commodities and flows, a downstream operator for other commodities and flows, and as a trader for intra-organisational transactions.

Therefore, there is often not a single answer to the question of whether a company is an  upstream or a downstream operator. This can only be resolved by conducting a detailed mapping of product flows.

Key questions for scoping EUDR exposure include:

• Is the product in scope under Annex I?
• Where is the product produced?
• Who performs customs clearance?
• Who first places the product on the EU market?
• Has a DDS already been completed upstream?
• Is the product being sold within the EU, imported, exported, or re-imported?

The answers to these initial scoping questions help determine whether a company is likely to have full due diligence responsibilities as an operator or more limited downstream obligations. Our recommendation is to answer these questions product-by-product and flow-by-flow, taking into account multiple entities that could be included within the group of companies.

Interestingly, many of the businesses that we work with initially assumed they had full compliance obligations, only to discover they had very limited responsibilities as downstream operators.

Understanding the downstream operator role

The recent European Commission guidance has helped clarify the role of downstream operators. Where an upstream operator has already conducted due diligence and submitted a DDS, downstream operators have a more passive compliance role. Their responsibilities are focused solely on maintaining records passed on to them by upstream operators.

Downstream operators do not need to:

• Proactively request DDS information from upstream operators unless there are substantiated concerns of violations.
• Pass DDS reference numbers further down the supply chain.

As promised by the European Commission, this clarification of the role of downstream operators significantly reduces their workload.

However, many downstream operators will still find themselves in the situation where their own customers will be asking for some evidence of EUDR readiness and EUDR compliance. Our advice for downstream operators is to prepare an EUDR Process Statement for sharing with customers.

These statements typically take the form of an externally focused policy document that clearly outlines a company’s EUDR role, supply chain position, and existing processes and governance in place. Although EUDR Process Statements are not legally required, they are extremely helpful for downstream operators in these circumstances, and we typically encourage companies to proactively share them with their customers to demonstrate best practice.

Determining products in scope

In theory, the products and commodities that are within the scope of the EUDR are clearly determined by HS codes in Annex I. However, business reality is often different and determining whether a product falls within scope remains another major challenge that companies are facing.

For example, packaging used solely to support, protect, or carry another product is generally not considered a standalone in-scope product. A cardboard presentation box surrounding a bottle would therefore typically be treated as packaging rather than a separate regulated product. However, if a company imports empty packaging from outside the EU, it is considered an in-scope product for EUDR purposes, even if the company then uses this packaging for the protection of its products, which are then sold on the EU market.

Other slightly confusing examples are products that may contain in-scope ingredients but are not themselves covered by the EUDR (i.e., are not included in Annex I). This includes perfume mixtures containing palm-derived chemicals or cars with rubber tyres.

Yet another example is products that are listed in Annex I but may or may not be in scope depending on the nature of the key ingredient/component (natural vs. synthetic). This applies to rubber bands, for instance, which are in scope if they are made of natural rubber but are out of scope if they are made of synthetic rubber. Another example is used cooking oil, which would only trigger EUDR application if it is derived from a relevant commodity (e.g. palm oil or soy) and is not considered waste/recycled material.

Additionally, the reality for many companies is that nicely organised HS codes might not be available for all potentially affected products. We see this with pharmaceutical companies and for businesses that are evaluating whether any of their spare parts are affected by the EUDR. For companies that are obviously upstream operators, HS codes are often clear. For downstream operators, it may be a big task in and of itself to collect HS codes and analyse whether they are in scope of the EUDR.

The EUDR is about more than importing and exporting

Another common misconception is that the EUDR only applies to companies importing and exporting finished products into and out of the EU. In reality, obligations can arise whenever a company places a relevant commodity or product on the EU market, which may include purchasing products for internal use, such as spare parts used in factories, rubber gloves used in laboratories, or even furniture used in offices. If these products are imported from outside the EU, these are EUDR-affected flows that need to be evaluated.

Another complexity arises for businesses involved solely in intra-EU transactions without any imports or exports. These businesses may still have obligations under the regulation, depending on their role in the supply chain. For example, a company purchasing an in-scope finished product from another EU-based company may still have obligations as a downstream operator or trader, including maintaining DDS records passed on to them by upstream operators.

In addition, there is an interesting re-import scenario that surprises quite a few businesses, which initially expect a significantly higher compliance burden. The recent guidance from the European Commission clarified that if an in-scope product (e.g. paper) was already placed on the EU market and then exported to a non-EU country (e.g. the UK), then transformed into another product (e.g. paper diaries) and then imported back to the EU, it can be considered as a re-import with the same underlying commodities (paper / wood) that has already been through due diligence processes and therefore does not require a repeat of due diligence.

Re-importers are considered downstream operators but have slightly more extensive obligations, as they must demonstrate at the customs border that the products qualify as re-imports, which may include DDS numbers passed on to them by upstream operators, invoices, contract documentation, etc. This is also the case where the European Commission clarifies that it will be acceptable to use conventional reference numbers in situations where re-importers as downstream operators far removed from upstream operators do not have access to actual DDS reference numbers.

Not every company needs a sophisticated EUDR digital tool

Another common misconception we encounter is that EUDR compliance automatically requires investment in a complex digital platform. The reality is far more nuanced, even for businesses considered upstream operators.

While technology can play an important role in managing EUDR compliance, the appropriate solution depends on a company’s role in the supply chain, the volume of transactions it handles, and the nature of its obligations. Many organisations are surprised to discover that the most sophisticated – and often most expensive – tools are not always necessary for their specific circumstances. We advocate for three broad approaches to EUDR compliance: dedicated external due diligence platforms, public-data-based due diligence approaches, and DDS reference number management for downstream actors. Each has its place, but they serve different needs.

For upstream operators responsible for conducting full due diligence and generating large volumes of DDSs, specialised tools can provide significant benefits. These platforms may support supplier engagement, geolocation management, deforestation risk assessments, audit readiness, and integration with enterprise resource planning (ERP) systems. For businesses managing thousands of suppliers or complex sourcing networks, automation can help reduce administrative burden and improve consistency.

However, not every company falls into this category. In some situations, organisations can perform due diligence using publicly available datasets and tools – such as the Whisp platform – to assess deforestation risk before manually submitting a DDS through TRACES. This approach may be suitable for lower-volume or less complex scenarios where a fully integrated platform would provide limited additional value.

In our advisory work, we have also encountered situations where some businesses, even when acting as operators, do not need to conduct deforestation risk assessments at all. This simplified due diligence applies to businesses importing from low-risk countries, as defined by the European Commission through the official EUDR benchmarking and country classification system. Simplified due diligence, or SD, still involves data collection, including geolocations, but upstream operators in this situation do not have obligations to conduct risk assessment and mitigation at all, and therefore do not require any digital EUDR solution, other than a means of collecting origin data from its suppliers, which can be done using existing digital questionnaire solutions – or even entirely manually through email, Excel, or Microsoft Forms.

Perhaps most importantly, many downstream operators and traders are likely to need far less functionality than they initially assume. Where due diligence has already been completed upstream, compliance is centred on retaining DDS reference numbers, which downstream operators do not even need to proactively request from upstream operators. Therefore, a digital data collection solution may not be required for downstream operators at all. In these cases, the most effective solution may simply be integrating key EUDR data fields – such as DDS reference numbers, product quantities and HS/TARIC codes – into existing business systems.

Looking ahead

As the EUDR implementation deadline approaches, many organisations are discovering that their biggest challenge is not collecting geolocation data or understanding due diligence requirements – it is determining where they sit within complex supply chains.

The distinction between upstream operator, downstream operator, trader, and out-of-scope entity fundamentally shapes a company’s compliance obligations.

Businesses that invest time now in mapping trade flows and documenting their role will be significantly better positioned to respond to customer requests, supplier inquiries, and regulatory scrutiny.

The good news is that many of the most common EUDR challenges can be resolved through careful role mapping and supply chain analysis. Getting this foundation right is often the first and most important step toward an effective compliance programme.

At Anthesis, we support companies across sectors in identifying their obligations under the EUDR, engaging suppliers and collecting necessary supply chain data, and preparing for compliance with the right tools in hand.

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