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.