Who qualifies as an operator under the Regulation?

An operator, according to Article 2(15) of the Regulation, refers to individuals or entities involved in commercial activities, including importing, or exporting relevant products.

This definition encompasses companies converting one Annex I product into another. For instance, if EU-based company A imports cocoa butter (HS code 1804, Annex I) and company B uses it to produce chocolate (HS code 1806, Annex I), both are operators.

Moreover, operators introducing Annex I products without prior due diligence (e.g., importers sourcing cocoa) must submit a due diligence statement, regardless of their size.