If you purchase timber that has already been placed on the EU market , rather than being the first to import it , you qualify as a Trader under EUDR. This distinction carries different, but still significant, compliance responsibilities.
Trader vs. Operator: The Core Distinction
An operator is the first to place a product on the EU market. A trader buys or sells products already in the EU supply chain. If you source timber from EU-based sawmills, you are likely a trader , the sawmills are the operators. The assumption that FSC-certified suppliers mean automatic compliance needs to be re-examined.
Trader Obligations
Traders have lighter obligations than operators, but they are not exempt:
- Maintain supplier records for five years , invoices, contracts, and supplier information
- Ensure suppliers comply with EUDR requirements and hold valid due diligence statements
- Demonstrate compliance if authorities request documentation
- Verify the DDS reference numbers from your operators and keep them on file
A Step-by-Step Framework for Traders
- Know your supplier: Verify if they are operators and EUDR-ready
- Get the docs: Request due diligence statement references from suppliers
- Keep records: Retain invoices, contracts, and supplier information for five years
- Assess risk: Flag any concerning discrepancies in the documentation
How Timberhub Helps Traders
The platform enables traders to centralise supplier data, automatically monitor compliance status, and receive alerts about changes affecting their supply chain. Rather than maintaining records manually across spreadsheets and email chains, the documentation is structured and accessible when authorities request it.
"Even if you're not the first to place timber on the EU market, EUDR still affects you. Traders play a crucial role in maintaining transparent and responsible supply chains."