The EUDR also applies to the domestic production and further processing of products listed in Annex I to the Regulation (EUDR products). Under the Regulation, your role may be that of a micro or small primary operator, an operator, a downstream operator, or a trader. Your role determines your obligations.
In domestic production, the first entity placing a product on the market in the cattle or forest sector is, under the EUDR, either an operator or a micro or small primary operator.
A company that purchases EUDR products that have already been placed on the market earlier in the supply chain (through domestic production or import) and further processes them into new EUDR products is a downstream operator. A trader, in turn, purchases EUDR products that have already been placed on the market earlier in the supply chain and resells them within the EU.
Below you will find more detailed information on the roles of different companies in the domestic cattle and forest sectors. Further below, you will find a description of the measures required from micro or small primary operators, operators, downstream operators and traders.
Domestic Cattle Sector
In accordance with the policy guidance of the Ministry of Agriculture and Forestry, in Finland the holding where a calf is born is considered, under the EUDR, either a micro or small primary operator or an operator, depending on the size of the undertaking*.
Under the EUDR, the Finnish Food Authority will submit, on behalf of micro or small primary operators in the cattle sector, the information required for a one-time simplified declaration to the EUDR Information System. Information on the identifier of the simplified declaration will be communicated to the micro or small primary operator, who will then pass the identifier on to the purchaser of the animals. The identifier is not animal-specific, and therefore, as long as the identifier remains unchanged, communicating it once to the next company in the supply chain is sufficient. The Finnish Food Authority is planning the practical arrangements for communicating this information and will provide more detailed guidance before the Regulation becomes applicable.
Cattle holdings where no new calves are born, as well as slaughterhouses and other meat-sector establishments that manufacture or sell cattle products listed in Annex I, are, under the EUDR, downstream operators or traders. More information on their obligations is provided below on this page.
Barn investments and measures promoting biodiversity may continue under certain conditions. The Ministry of Agriculture and Forestry has analysed the guidance document published by the Commission, according to which the interpretation has been further clarified (Ministry of Agriculture and Forestry press release of 16 January 2025 in finnish and Ministry memorandum of 17 January 2025 in finnish).
Domestic Forest Sector
In accordance with the policy guidance of the Ministry of Agriculture and Forestry, in Finland, as regards timber, the buyer of the timber (standing timber sales) is generally considered the operator. In sales at delivered price and delivery sales, the operator is the forest owner or the seller of the timber.
If the operator is a micro or small enterprise, i.e. a micro or small primary operator, it may submit a simplified one-time declaration. An authorised representative may be used to submit the declaration, if desired.
Medium-sized and larger operators submit a due diligence statement (DDS) for the products concerned.
Micro or Small Primary Operator
Under the Regulation, a micro or small primary operator means an operator that:
- is a natural person or a micro-enterprise or small enterprise;
- (*) Thresholds for a small enterprise: balance sheet total: EUR 7.5 million, net turnover: EUR 15 million, employees: 50 (one of these thresholds may be exceeded). Only those parts of the business that are related to EUDR products are taken into account when determining the size category.
- is established in a country classified as a low-risk country in accordance with the Regulation; and
- in the course of a commercial activity places products on the market or exports products that the operator has itself grown, harvested or obtained from relevant plots of land or, in the case of cattle, raised on holdings located in that country.
Measures Required from Micro or Small Primary Operators
- Submit an electronic one-time simplified declaration in the EUDR Information System before placing products on the market or exporting them. The information may be updated if significant changes occur after submission of the declaration.
- Significant changes could include, for example, the consolidation of properties or the commencement of production of entirely new commodities.
- Provide the buyer of the products with the identifier of the simplified declaration, excluding consumer customers.
- Continue to comply with sector-specific legislation as before.
- Please note that:
- the harvesting of primary forests is, as a rule, contrary to the EUDR;
- converting forest land to agricultural use causes deforestation within the meaning of the Regulation.
Measures Required from Operators
- Check whether your product is listed in Annex I to the Regulation to determine whether it falls within the scope of the Regulation's obligations.
- Operators must have a due diligence system (DD system) in place to ensure that products placed on the market comply with the Regulation.
- Collect the required information on the products by applying the DD system.
- Where necessary, carry out a risk assessment and risk mitigation measures for the products by applying the DD system.
- Submit a due diligence statement (DDS) in the EUDR Information System before placing products on the market.
- Provide the buyer of the products with the reference number of the DDS relating to the products if the buyer remains subject to obligations under the EUDR.
- Retain information relating to DDS submissions for at least five years.
- Notify the competent authority and the companies to which you have supplied products of any cases that come to your attention that include indications of possible non-compliance. See Article 4(5).
- Large undertakings are required to publish annual public reports on their due diligence system (DD system).
Measures Required from Downstream Operators and Traders
The EUDR imposes the most extensive obligations on the first entity placing a product on the market. For example, the first entity placing a product on the market may be an importer from outside the EU. After this stage, the obligations are lighter and the company's role is either that of a downstream operator or a trader. These two roles are subject to the same obligations:
- Check whether your product is listed in Annex I to the Regulation to determine whether it falls within the scope of the Regulation's obligations.
- You are a downstream operator if you purchase, from the EU internal market, a product for which due diligence has already been carried out and further process it into new products listed in Annex I to the Regulation.
- Large undertakings must register in the EUDR Information System before placing products on the market, making them available on the market, or exporting them.
- Collect and retain, for at least five years, information about suppliers of the products and the companies to which you supply products. Retain the company name, registered trade name or trademark, address details, email address and website.
- If the supplier of the products is an operator within the meaning of the Regulation, you will receive the reference number of the DDS or the identifier of the simplified declaration relating to the products. Retain the reference number or identifier for at least five years.
- Notify the competent authority and the companies to which you have supplied products of any cases that come to your attention that include indications of possible non-compliance. Large undertakings are subject to additional obligations. For further information, see Article 5(6) and Large Undertakings & EUDR.
- Please note: If you further process products into products that are no longer listed in Annex I to the Regulation, you are not subject to any obligations under the EUDR. For example, purchasing chocolate from an importer for the manufacture of biscuits does not fall within the scope of the EUDR, as biscuits are not listed in Annex I.