I am both an importer and a trader – what does that mean for me

Both obligations apply, and not alongside each other but cumulatively

If you import products from outside the EU yourself and then resell the same or other products within the EU, you are a supplier for the import and a trader for the resale — and this means that for the import part of your activities the full obligations apply: due diligence with a risk assessment per product stream and a due diligence statement that is submitted to the EU information system. Which role applies exactly to which part of your activities and what obligation goes with it is precisely why the role check for supplier or trader a good starting point: the two roles are assessed per product stream, not per company as a whole.

The distinction that matters here is not "am I an importer or trader" but "am I bringing this product to the EU market for the first time". For the part of your trade where you resell products that were already imported — meaning your company did not itself arrange the import from a third country — a lighter set of obligations applies, comparable to what applies to companies that operate exclusively downstream. What is and is not required in that case is described on the page about what applies to those who only resell what is already on the EU market. For the import part of the same enterprise, however, the full due diligence remains applicable, including geodata of the parcels of origin and the associated record-keeping obligation.

Where this is based: the definitions in Article 2

The Regulation defines supplier and trader in Article 2 of Regulation (EU) 2023/1115 as two distinct roles, linked to the question of who brings the product to the EU market for the first time and who trades it thereafter; an enterprise can act as a supplier for one product part and as a trader for another, with the associated obligations under the same regulation. Regulation (EU) 2025/2650 has eased the submission deadlines and some obligations, but has not changed the starting point that the role is determined per activity within the chain.