What must I do if I only resell what is already on the EU market?

Resellers are usually 'traders', not 'operators'

If you exclusively resell products that another company has already placed on the EU market, you generally fall under the regulation in the role of "trader" rather than "operator". This distinction is crucial, because an operator is the party that places the product on the EU market for the first time or exports it from the EU, and that party bears the heaviest burden: full due diligence, including geolocation data of plots and risk assessment. A trader further down the chain generally builds on what has already been established beforehand.

Within the trader role, company size makes a difference. A trader that is not an SME is treated as equivalent to an operator for compliance purposes and must therefore conduct due diligence itself. A trader that is an SME has a lighter obligation: maintain records of suppliers and parties to whom products have been supplied, and where applicable the reference number of the due diligence declaration issued earlier in the chain. If there is reason to believe that a product does not comply with the rules, this entails an obligation to act: stop placing it on the market, inform the competent authority, and take corrective measures. Which of these two routes applies exactly, and from which date, depends on the combination of role, SME status, and product — this is precisely what the role check was created for.

What Article 2 and Article 5 of Regulation (EU) 2023/1115 provide

The definitions of "operator" and "trader" are set out in Article 2 of Regulation (EU) 2023/1115, and the obligations that apply specifically to traders — including the distinction between SMEs and non-SMEs — are detailed in Article 5. Regulation (EU) 2025/2650 subsequently adjusted the timeline and some implementation details, with different effective dates per category of operator or trader; the exact dates are in that amending regulation itself.