My Indian group has a subsidiary in the European Union (EU). Who is the operator under the EU Deforestation Regulation (EUDR), the parent or the subsidiary?

The Commission says due diligence obligations relate to legal entities, not company groups. The operator that places the product on the EU market or exports it is responsible, and its name goes on the due diligence statement. The group's internal organisation is not governed by the Regulation.

What the Commission says

• Due diligence obligations relate to legal entities, rather than to company groups.
• The internal organisation and due diligence policy of a mother company and its subsidiaries is not governed by the Regulation.
• The operator that places the relevant product on the EU market, or exports it, is responsible for the compliance of the product and for overall compliance. Its name is the one that should be provided in the due diligence statement or simplified declaration, and it retains full responsibility.

Our reading for an Indian parent

• If the EU subsidiary imports the goods, it is the operator, and the Indian parent is the supplier. The parent supplies the plot data and legality records.
• If the Indian parent itself imports into the EU, see our page on whether an Indian exporter with its own EU customs registration is an operator.
• Different group companies can hold different roles on different shipments, so do not assume one answer for the whole group.

A practical split

• Write down, per shipment route, which legal entity imports, which files the statement, and which keeps the records.
• A group can appoint one EU member as authorised representative to file for the others. The named operator still carries the responsibility. Do not rely on a group policy alone to cover the filing entity.

What Senseible does here

Senseible reads the HS code on each purchase invoice and keeps every invoice dated, so you can show your buyer what came in, from whom and when. Plot coordinates come from your growers and your buyer files the statement. We do not file statements or certify deforestation-free status.

• Do I count as an EUDR operator if I import?
• What an Indian supplier gives the EU importer for the statement
• Does EUDR apply to my Indian exports?
• EUDR readiness: what applies to your goods

Sources: European Commission Green Forum, Understand due diligence under the EU Deforestation Regulation, European Commission Green Forum, EUDR roles and responsibilities

Last reviewed 2026-11-05. The group rule is quoted from the Commission due diligence page, which cites Frequently Asked Questions (FAQs) 3.13 and 5.3. The operator for a specific shipment depends on the facts, so confirm it with advisers.