A source-specific role term: under EUDR, the market/export actor; under CBAM, the installation-control actor.
Operator is a role term whose meaning depends heavily on the legal regime, which is why it cannot safely be treated as a universal business label. The practical task is to record which source regime applies and which regulated activity makes the actor responsible.
This page displays both EUDR and CBAM official definitions. Keep the EUDR market/export actor meaning separate from the CBAM operator installation-control meaning, especially when the same supplier group appears in both product and emissions evidence flows. In EUDR, the operator places relevant products on the market or exports them.
Regulation (EU) 2023/1115 on deforestation-free products
any natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them;
Reference: Article 2, point 15
Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism
any person who operates or controls an installation in a third country;
Reference: Article 3, point 31
Reviewed public draft page. Aligns with EUDR high-priority policy: source-bound scope/role boundaries, concrete origin and market-activity records, and traceability-focused commentary.
Operator is a role term whose meaning depends on the source regime. In EUDR, it is the market/export actor placing relevant products on the market or exporting them in the course of commercial activity; in CBAM, it is tied to operating or controlling an installation in a third country.
EUDR applies to the listed commodities and derived products placed on or exported from the EU market from 30 December 2024 (large operators) and 30 June 2025 (SMEs), subject to the benchmarking system that classifies countries as low, standard, or high risk. The applicable obligation level depends on country risk classification as well as operator size.
Implementation records should capture actor identifier, regulated activity, source regime, responsibility record, product or installation link, market/export event, role date, supporting mandate or control evidence, and relationship to trader, importer, customs declarant, or authorised CBAM declarant roles.
Operator is a role-routing term. Evidence duties should be linked to the source-specific activity that creates responsibility, so EUDR origin evidence and CBAM installation evidence do not get assigned to a generic business contact.