Operator or trader? The roaster question and the HS-code rule
Your role under the EUDR sets your obligations. For coffee, the deciding factor is often whether processing changes the HS code.
Updated 7 June 2026, 4 min read
The EUDR distinguishes operators (who place a product on the market or export it) from traders (who make it available further down the chain). The obligations differ, so getting the role right per transaction matters.
The HS-code change rule
The Commission's FAQ (3.1.1) ties the distinction to the Harmonised System code. If processing changes the first four digits of the HS code (the first two for paper and pulp, chapters 47 and 48), the actor becomes a downstream operator. If the first four digits are unchanged, the actor is a trader.
Roasting coffee moves it from 0901 11 (not roasted) to 0901 21 (roasted). The first four digits, 0901, are unchanged, so a roaster who buys EU-placed green coffee is a trader, not a downstream operator.
Why it matters
Only the first downstream actor collects and records the due-diligence statement reference (Art. 5(3)(a)); the statement does not have to be regenerated at every step. Modelling the chain correctly avoids both over-reporting and gaps.
In Sylva
Each case carries its own role, so the same organisation can be an upstream operator on one batch and a trader on another, with the right obligations attached to each.
Sources
Sylva is compliance software, not legal advice. Verify obligations against the consolidated EUDR text on EUR-Lex.