Page updated 04/2026 to reflect the amendment regulation.
When products that have already been placed on the EU market and for which a due diligence statement (DDS) or a simplified declaration has been submitted are sold, this constitutes trading within the meaning of the EU Deforestation Regulation (EUDR). Those who sell products later in the supply chain after the operator are considered traders. Under the EUDR, domestic trade is treated in the same way as trade within the EU.
Measures required from traders
- Check whether your product is listed in Annex I to the EUDR to determine whether it falls within the scope of the Regulation’s obligations.
- 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 the suppliers of the products and about the companies to which you supply the products. Keep records of the company name, registered trade name or trademark, address details, email address and website.
- Ensure that you receive the DDS reference number or the simplified declaration identifier related to the products if the supplier of the products is an operator.
- 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 have additional obligations. See in more detail Article 5(6) of the amending Regulation and the Finnish Food Authority’s page Large undertakings and the EUDR.
Example 1:
If you purchase wooden furniture from an importer and sell it in your shop, you are considered a trader.
What is the difference between ‘placing on the market’ and ‘making available on the market’?
Placing on the market refers to the first time a product is made available on the EU market. This includes a situation in which a product is imported into the EU from a third country or manufactured within the EU and placed on the market for the first time.
In the context of the EUDR, making available on the market refers to a situation, for example, in which a product or commodity has already been placed on the EU market once and is subsequently traded within the EU.
See Article 2(16) and (18) of the EUDR.