From the summary:
> Developers who make money from the App Store through either an upfront purchase price or through in-app purchases are considered traders, regardless of size
Developers who do not make any revenue, are not considered traders.
Or from Apple's announcement itself: "How to know if you are a trader".
> For example, if you're a hobbyist and you developed your app with no intention of commercializing it, you may not be considered a trader.
From the Apple page, requiring the info:
> If you’re a trader, you’ll need to provide your trader information before you can submit your app for review.. -- https://ancillary-proxy.atarimworker.io?url=https%3A%2F%2Fdeveloper.apple.com%2Fne...
"IF".
Simply posting an app to the EU store, does not make one a trader.
> You must assess whether you are a trader for EU law purposes. Apple can't determine whether you're a trader. ( https://ancillary-proxy.atarimworker.io?url=https%3A%2F%2Fdeveloper.apple.com%2Fhe... )
> The DSA defines a trader as “any natural person, or any legal person irrespective of whether privately or publicly owned, who is acting, including through any person acting in his or her name or on his or her behalf, for purposes relating to his or her trade, business, craft or profession.” -- https://ancillary-proxy.atarimworker.io?url=https%3A%2F%2Fdeveloper.apple.com%2Fhe...
> To determine if you're a trader, you should consider a range of non-exhaustive and non-exclusive factors (see those listed on page 2 in the EC’s Guidance), which may include:
> Whether you make revenue as a result of your app, for example if your app includes in-app purchases, or if it's a paid or ad-sponsored app — especially if you're transacting in large volumes;
> Whether you engage in commercial practices towards consumers, including advertising, or promoting products or services;
> Whether you're registered for VAT purposes; and
> Whether you develop your app in connection with your trade, business, craft, or profession—meaning that you’re acting in a professional/business capacity. You're unlikely to be a trader for EU law purposes if you're acting “for purposes which are outside your trade, business, craft, or profession.”