Am I an operator or trader under the EUDR?

An economic operator is whoever places the product on the EU market for the first time; a distributor is whoever sells it on after that

The role that applies to you depends on where you stand in the chain at the moment the product enters the EU market. An economic operator is the one who places coffee, cocoa, wood, rubber, soy, palm oil, cattle or products derived from them on the EU market for the first time, or who exports from the EU. This is typically the importer who sources the goods directly from a third country. A distributor is someone who makes such a product, already placed on the market earlier, available for further trade — that is, resells it within the EU without having been the initial importer themselves.

For SMEs that both import and resell, the distinction is not always a matter of one label for the entire company. The same company can be an economic operator for one product stream — for example when directly importing cocoa beans — and a distributor for another stream, if it purchases an already-imported product from another EU party and supplies it further. The classification follows the product stream, not the undertaking as a whole, and this subsequently determines which obligation applies and from which date.

What this is based on: the definitions in Article 2 of Regulation (EU) 2023/1115

The distinction between economic operator and distributor stems from the definitions in Article 2 of Regulation (EU) 2023/1115, and the associated obligations are set out separately: those of the economic operator in Article 4, those of the distributor in Article 5. Regulation (EU) 2025/2650 has adjusted the implementation dates and a number of implementation aspects, but the core of the distinction between the two roles lies in the original regulation. For the precise wording and the exceptions that apply, the text of both regulations on EUR-Lex is the appropriate source.