EUDRChecklistEU

EU Deforestation Regulation Checklist

A concrete checklist for deciding whether an EUDR product movement can proceed, what evidence must be held, and which reference numbers must travel through the supply chain.

Use it for procurement, sustainability, trade compliance, and customs-readiness reviews before placing, making available, or exporting relevant products.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

The EU Deforestation Regulation applies to relevant commodities and listed derived products only when the product is deforestation-free, produced in accordance with relevant legislation in the country of production, and covered by the required due diligence statement or simplified declaration. This checklist turns those conditions into records a team can actually verify.

Section 1

1. Confirm EUDR role, commodity, and product scope

Start by classifying the business role for the specific movement: operator placing a relevant product on the EU market or exporting it, downstream operator using products already covered by a due diligence statement or simplified declaration, or trader making products available on the market.

Then match the commodity and derived product against Annex I instead of relying on product-family assumptions. EUDR scope is built around cattle, cocoa, coffee, oil palm, rubber, soya, and wood, plus the products listed for those commodities.

  • Record the role: operator, downstream operator, trader, or micro or small primary operator if the special definition is met.
  • Record the market action: placing on the market, making available on the market, or exporting.
  • Map each SKU, customs line, or shipment item to the relevant commodity and the Annex I product description or code used for the scope decision.
  • Stop the release if the product is in scope and no due diligence statement, simplified declaration identifier, or upstream reference chain is available.
  • Keep out-of-scope decisions narrow: identify the checked product, the commodity considered, and why Annex I did not capture that item.
Sources for this answer
Consolidated Regulation (EU) 2023/1115
Supports the EUDR scope trigger, covered commodities and derived products in Annex I, and the role distinctions between operators, downstream operators, traders, and micro or small primary operators.
Section 2

2. Build the supplier and origin evidence file

For each in-scope product, create a supplier evidence file before the commercial release. The file should prove who supplied the product, where the commodity was produced, and whether an upstream due diligence statement or simplified declaration already exists.

Downstream operators and traders need supply-chain information, including supplier details and relevant reference numbers or declaration identifiers when the supplier is an operator. Keep the file structured enough to answer competent-authority questions without reconstructing the chain from emails.

  • Supplier identity and contact details for the immediate supplier.
  • Product, quantity, batch, lot, purchase order, invoice, shipment, and customs-reference fields used to link evidence to the physical goods.
  • Country of production and the specific plot, establishment, farm, plantation, forest, or facility evidence used by the supplier.
  • Upstream due diligence statement reference number or simplified declaration identifier, when the supplier provides one.
  • Downstream recipient details when the company passes products further through the supply chain.
Sources for this answer
Consolidated Regulation (EU) 2023/1115
Supports the need to collect and keep supply-chain information, supplier details, downstream recipient details, and upstream due diligence statement references or declaration identifiers.
Section 4

4. Complete risk assessment and mitigation before release

EUDR due diligence is not complete after data collection. The operator must assess risk and may place on the market or export only where the assessment reveals no or only negligible risk of non-compliance.

If risk is not negligible, risk mitigation measures must be adopted before the product is placed on the market or exported. Low-risk production can reduce the assessment and mitigation burden only where the conditions for simplified due diligence are met, including checks for supply-chain complexity and risk of circumvention or mixing.

  • Assess whether the supplier evidence, origin evidence, and geolocation records support a no-or-negligible-risk conclusion.
  • Check country or regional risk classification, but do not treat low-risk production as automatic clearance if supply-chain complexity or mixing risk remains unresolved.
  • Document risk factors such as incomplete supplier evidence, unexplained origin changes, mixed lots, missing legal-production documents, or unsupported deforestation-free claims.
  • Define mitigation actions before release: supplier clarification, additional documents, segregation, independent checks, shipment hold, substitution, or rejection.
  • Approve release only when the remaining risk is documented as no or negligible.
Sources for this answer
Consolidated Regulation (EU) 2023/1115
Supports the Article 8 due diligence sequence of information collection, risk assessment, and risk mitigation, plus the no-or-negligible-risk release condition and simplified due diligence conditions for low-risk production.
Section 5

5. File the due diligence statement and pass reference numbers downstream

Operators submit the due diligence statement through the Article 33 information system before placing relevant products on the market or exporting them. If an authorised representative submits it, the operator still retains responsibility for EUDR compliance.

After filing, keep the reference number with the commercial record and communicate the due diligence statement reference number, declaration identifier, or other applicable upstream reference to downstream operators and traders.

  • Confirm the entity that must submit: operator, authorised representative, or micro or small primary operator using a simplified declaration where applicable.
  • Prepare the Article 33 filing package from the approved scope, origin, geolocation, risk assessment, and mitigation records.
  • Record the due diligence statement reference number or simplified declaration identifier in the order, shipment, customs, and customer-facing compliance file.
  • Block downstream transfer if the required reference number or declaration identifier is missing from the supply-chain handoff.
  • For non-SME downstream operators and non-SME traders, confirm information-system registration before placing, making available, or exporting relevant products.
Sources for this answer
Consolidated Regulation (EU) 2023/1115
Supports due diligence statement submission before placing on the market or export, operator responsibility, downstream communication of reference numbers, simplified declaration identifiers, and information-system registration for certain downstream operators and traders.
Commission Implementing Regulation (EU) 2024/3084
Identifies the Commission implementing act for the EUDR information system used for due diligence statements and related filings.
Section 6

6. Retain records and prepare for customs or authority checks

The EUDR checklist should close with a retention and customs-readiness review. Operators keep due diligence statement records for five years, and downstream operators and traders keep Article 5 supply-chain information for at least five years and provide it to competent authorities on request.

For import and export operations, customs and trade-compliance teams need the same reference numbers and release evidence that procurement and sustainability teams used. Do not wait until border clearance to discover that a shipment lacks the Article 33 filing reference or the upstream declaration identifier.

  • Store the due diligence statement, statement reference number, simplified declaration identifier, or upstream reference chain with the shipment and product master data.
  • Retain supplier, geolocation, legal-production, risk assessment, mitigation, and downstream-recipient records for the required five-year evidence period.
  • Make records searchable by supplier, product, batch, country of production, shipment, customs entry or export reference, and due diligence statement reference number.
  • Create an escalation path for relevant new information indicating that a product already placed, made available, or exported may be non-compliant.
  • Before import or export release, confirm the customs broker or trade-compliance team has the EUDR reference fields needed for the declaration and authority response file.
Sources for this answer
Consolidated Regulation (EU) 2023/1115
Supports five-year retention for due diligence statements and supply-chain information, competent-authority access, and obligations to respond when new information indicates possible non-compliance.
European Commission EUDR overview
Supports the public Commission overview context for the EU Deforestation Regulation and its entry-into-application framing.
Recommended next step

Turn EUDR checks into a release-ready evidence file

Use this checklist to connect product scope, supplier evidence, geolocation, risk review, due diligence statement references, and customs handoff before an EUDR product movement proceeds.

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Primary sources

References and citations

Consolidated Regulation (EU) 2023/1115
eur-lex.europa.eu
Referenced sections
  • Supports five-year retention for due diligence statements and supply-chain information, competent-authority access, and obligations to respond when new information indicates possible non-compliance.
"at least five years"
European Commission EUDR overview
environment.ec.europa.eu
Referenced sections
  • Supports the public Commission overview context for the EU Deforestation Regulation and its entry-into-application framing.
"EUDR overview"
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