Who qualifies as non-SME traders, and what responsibilities do they have?

Non-SME traders are businesses that do not fall under the category of small and medium-sized enterprises, as defined in Article 2(30) of the EUDR, referencing Article 3 of Directive 2013/34/EU. These typically include large-scale retail chains or supermarkets.

Under Article 5(1) of the Regulation, large traders share the same obligations as downstream operators:

– Submission of a due diligence statement.

– Ability to reference previous due diligence in the supply chain when submitting their statement.

– Legal liability in case of Regulation breach, including for due diligence conducted by upstream operators.