EU Deforestation Regulation Checklist

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.

Check the current Annex I entry and its notes after the changes made by Delegated Regulation (EU) 2026/2102, effective 18 September 2026. Save the code, product description, exclusion and application date in the SKU record. Specified cattle hides and leather entries were removed; additions such as coffee extracts start on 30 December 2027. A classification copied from the December 2025 consolidation needs to be checked again.

For each in-scope product, create a supplier evidence file before the commercial release. The record 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.

For operators subject to Article 9, information collection includes evidence for geolocation and for production that is deforestation-free and lawful under the relevant legislation of the country of production. Treat geolocation as a product-release field, not as optional sustainability context.

Article 4a(5) allows the postal address of all relevant plots or the cattle establishment to replace geolocation only for a qualifying micro or small primary operator. Confirm own production in the low-risk country where that qualifying actor is established before using this route; small-business status alone is insufficient.

Unless Article 13 simplified due diligence applies, 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.

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, the operator keeps the reference number with the commercial record and communicates the DDS reference number or declaration identifier downstream under Article 4(7). Article 5(3)(a) requires a downstream operator or trader to collect the identifier only when its immediate supplier is an operator; it does not require every later recipient to collect it.

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.

Where Article 26(4) applies, customs must receive the DDS reference number or simplified declaration identifier before release for free circulation or export. That paragraph excludes exports by downstream operators. Record the actor role before assigning the customs-reference task; the downstream operator still needs its Article 5 information.