Yes. Database and Forum are managed by two different login systems. Forum is opened to everybody but, in database, advanced features (such as download option, saving queries, creating commodity/country groups) reserved for subscribers.
By default, all database users will be authenticated as "Guest User" that can view on-screen but no download option.
As an alternative, you can access part of UN Comtrade data via UNdata (data.un.org), there you will be able to download up to 50,000 records per query.