Build EUDR compliance around the legal sequence: product scope, actor role, information, Article 10 risk assessment and Article 11 mitigation where required, and a statement before EU market placement or export.
This page focuses on what operators, downstream operators, and traders need to evidence so a relevant product file can withstand independent review or competent-authority questions.
Regulation (EU) 2023/1115, the EU Deforestation Regulation (EUDR), makes compliance a release decision for each relevant product flow. Before the applicable date, identify the Annex I product and actor role, then show that the product is , was produced in accordance with relevant legislation of the country of production, and is covered by the required statement (DDS) or simplified declaration. Downstream operators and traders separately hold the Article 5 information required for their role. The main duties apply from 30 December 2026; Article 38(3) defers them to 30 June 2027 for qualifying natural-person operators or micro or small undertakings established as such by 31 December 2024, except for products covered by the former EU Timber Regulation Annex.
The first compliance file should identify the exact relevant commodity or Annex I product, the EU activity, and the actor role. Operators place relevant products on the market or export them. Traders make relevant products available on the market and are not operators or downstream operators. Downstream operators and traders have their own information, registration, notification, and recordkeeping duties where Article 5 applies.
Do not file a statement from a generic supplier questionnaire alone. The record should connect the product to the covered commodity, country of production, supplier chain, plot or establishment information, and the internal owner who can stop placement, availability, or export if the EUDR evidence is incomplete.
Keep product classification current when the Annex changes. Delegated Regulation (EU) 2026/2102 entered into force on 18 September 2026 and removed or qualified several entries, including specified cattle hides and leather. It also adds products such as coffee extracts from 30 December 2027. The release owner should record the amended entry and its date before relying on an older scope decision.
Sources (2)
Supports the actor-role distinction and the Article 3 market-access conditions used to scope the compliance file.
Binding product-scope changes effective 18 September 2026, with specified additional entries applying from 30 December 2027.
Operators need a system that runs before placing a relevant product on the market or exporting it. Unless Article 13 simplified due diligence applies, the system should combine information collection, Article 10 risk assessment, and Article 11 risk mitigation where the risk is not negligible. If the due diligence conclusion is no or only negligible risk, the operator makes the due diligence statement available through the Article 33 information system and assumes responsibility for Article 3 compliance.
The practical compliance owner is usually split across sourcing, sustainability, trade compliance, and legal. Sourcing obtains supplier and plot-level inputs; sustainability checks and legality evidence; trade compliance controls release and statement references; legal handles substantiated concerns, non-negligible-risk decisions, and competent-authority correspondence.
Sources (2)
Supports the operator sequence of Article 9 information collection, Article 10 risk assessment, Article 11 mitigation, due diligence statement submission, responsibility, and five-year DDS records.
The due diligence shall include: (a) the collection of information, data and documents needed to fulfil the requirements set out in Article 9; (b) risk assessment measures as referred to in Article 10; (c) risk mitigation measures as referred to in Article 11.
Supports the operational need to control due diligence statement submission through the EUDR information system.
on the functioning of the information system
This guide helps connect product scope, supplier evidence, Article 9 information, Article 10 risk assessment, Article 11 mitigation, and due diligence statement records before covered products move.
Downstream operators and traders should treat supplier references as controlled compliance data. Article 5 requires them to possess specified supply-chain information, including supplier details and statement reference numbers or declaration identifiers where the supplier is an operator, and to keep the information for at least five years.
Downstream operators and traders outside the micro, small and medium-sized enterprise (SME) categories have additional Article 5 controls. They register in the Article 33 information system before the relevant activity and must inform competent authorities when they obtain information indicating non-compliance before placement, availability, or export. Where they receive a substantiated concern, they must verify and must not proceed unless verification demonstrates no or negligible risk.
Sources (1)
Supports downstream operator and trader information, registration, notification, verification, and five-year recordkeeping duties.
information is the foundation for the rest of the EUDR compliance file. A useful record is structured enough for a reviewer to connect product, supplier, country of production, plot or establishment, legality evidence, and evidence without hunting through email attachments.
For the micro or small primary-operator route, record the size basis, own production, establishment in a low-risk country and production in that country. Keep the declaration identifier and, if used, the postal addresses of all relevant plots or the cattle establishment under Article 4a(5). A small reseller does not qualify through size alone.
Sources (1)
Supports the Article 9 evidence categories and the limited micro or small primary operator route, including geolocation, the permitted postal-address substitution, deforestation-free evidence, legality evidence, and authority availability.
A compliant EUDR risk assessment should explain why the product is no or negligible risk, not simply state that a supplier is approved. The record should evaluate production location, commodity and product characteristics, supplier reliability, supply-chain complexity, mixing or circumvention risks, and any substantiated concerns.
If risk is not negligible, Article 11 mitigation happens before the product is placed on the market or exported. The release decision should show which mitigation actions were required, who approved the result, and why the remaining risk is no or negligible. If the conclusion cannot be supported, the operator must not place the product on the market or export it.
Sources (1)
Supports the risk-assessment conclusion standard, mitigation of non-negligible risk before the regulated activity, and the limited Article 13 low-risk simplification.
Operators shall not place the relevant products on the market or export them, except where the risk assessment reveals no or only a negligible risk that the relevant products are non-compliant.
The statement is the controlled output of the EUDR file. Operators must not submit statements until the file, the applicable Article 10 assessment and Article 11 mitigation or Article 13 simplified-due-diligence checks, and release approval are complete.
Keep a file index for each DDS reference or declaration identifier so the team can answer an authority request. Include the product, supplier, origin, evidence, risk conclusion, mitigation record, authority communications, downstream reference communications, and retention owner.
Article 12 requires operators to review their system at least annually and whenever new developments could affect it. Keep a record of system updates for five years, and reopen affected product files when a changed supplier, origin, benchmark tier, substantiated concern, or evidence failure undermines the earlier conclusion.
Sources (2)
Supports the annual and event-driven due diligence-system review, five-year records of system updates and operator due diligence statements, and Article 5 downstream operator and trader information.
Operators shall keep a record of the due diligence statements for five years from the date the statement is submitted through the information system referred to in Article 33.
Supports the high-level Commission context for EUDR application planning and regulated-market readiness.
"The due diligence shall include: (a) the collection of information, data and documents needed to fulfil the requirements set out in Article 9; (b) risk assessment measures as referred to in Article 10; (c) risk mitigation measures as referred to in Article 11."
"on the functioning of the information system"
"The Information System shall be used by operators, and where applicable, their authorised representatives, for submitting and managing Due Diligence Statements and Simplified Declarations"
"Operators shall not place the relevant products on the market or export them, except where the risk assessment reveals no or only a negligible risk that the relevant products are non-compliant."
"The due diligence shall include: (a) the collection of information, data and documents needed to fulfil the requirements set out in Article 9; (b) risk assessment measures as referred to in Article 10; (c) risk mitigation measures as referred to in Article 11."
"Operators shall keep a record of the due diligence statements for five years from the date the statement is submitted through the information system referred to in Article 33."
Concise EU Deforestation Regulation answers on scope, covered commodities, operator and trader roles, due diligence statements, geolocation, low-risk countries, customs release, SME timing, enforcement, and records.
Test whether the EU Deforestation Regulation applies by checking Annex I product scope, EU market placement or export, operator/trader status, downstream role, SME status, and simplified due diligence conditions.
A practical EU Deforestation Regulation checklist covering product scope, supplier evidence, geolocation, risk assessment, mitigation, due diligence statements, recordkeeping, and customs readiness.
How EUDR country-risk benchmarking affects low-risk simplified due diligence, full due diligence, information collection, risk monitoring, and evidence records.
Use the official EUDR country list to route each production origin through low-risk simplified due diligence or full due diligence, with evidence and review triggers.
EUDR calendar covering application dates, the current country-risk act, the information system, timber transition rules, and preparation tasks by actor.
EUDR readiness guide covering the correct application cohort, role-specific first actions, geolocation evidence, due diligence statements, and country risk.
Build an EUDR evidence file for due diligence statements: Article 9 information, geolocation records, supplier proof, risk assessment, mitigation, reference numbers, and retention.
File an EUDR due diligence statement with the correct Annex II data, operator approval, Information System handoff, reference number, and retained evidence.
Prepare the mandatory EUDR Annex II due diligence statement fields and the internal evidence log that supports the operator's no-or-negligible-risk conclusion.
How to collect, check, and use EUDR geolocation evidence for relevant commodities and products, Article 9 information, risk assessment, supplier records, and due diligence statements.
Build an EUDR evidence file that links Annex I commodity scope, supplier and trader records, geolocation evidence, product lots, risk assessment, and due diligence statement support.
How to structure EUDR traceability records for geolocation, supplier evidence, product lots, risk assessment inputs, and due diligence statement handoffs.
How to check EUDR scope for the seven commodities, Annex I relevant products, operator and trader roles, and the evidence needed to support a scope decision.
EUDR enforcement guide covering risk-based checks, no-warning inspections, interim measures, corrective action, penalties, and records by actor.
EUDR penalty guide explaining Article 25 fines, the 4% turnover rule, confiscation, temporary restrictions, corrective action, and national-law limits.
EUDR requirements based on official sources: scope, due diligence, geolocation, risk assessment, mitigation, DDS filing, records, and simplified regimes.
How to run an EUDR Article 10 risk assessment, decide when risk is not negligible, apply Article 11 mitigation, and keep release evidence before placing products on the EU market or exporting.
A practical EUDR supplier onboarding template for Annex I product scope, supplier roles, geolocation evidence, risk inputs, mitigation records, DDS references, and five-year records.
Compare EUDR product-level market controls with the current CSDDD company-scope thresholds, human-rights and environmental due diligence, application dates, evidence, and enforcement.
How to check whether a product is in EUDR Annex I, connect it to a covered commodity, and keep supplier and trade evidence without relying on unsupported code lists.
What EUDR country benchmarking means, how low-risk production affects simplified due diligence, and what operators still need to collect.
How to prepare EUDR due diligence statement references, information-system handoffs, importer checks, and release evidence before customs or export clearance.
FAQ on EU Deforestation Regulation DDS reference numbers, including operator submissions, downstream handoffs, Article 33 information-system context, and evidence records.
How EUDR teams should collect, link, and use plot-level geolocation evidence for due diligence statements, suppliers, consignments, and risk assessment.
FAQ guidance on EUDR information system filing, due diligence statement submission, declaration identifiers, downstream handoffs, representatives, and evidence retention.
FAQ on how EUDR Articles 10 and 11 handle non-negligible risk, when operators should stop placement or export, and what evidence belongs in the file.
Classify EUDR operators, downstream operators, and traders by product and transaction, then identify the due diligence, information, registration, and recordkeeping duties for each role.
When EUDR Article 13 simplified due diligence applies, what operators must still collect and submit, how mixing or circumvention defeats it, and which low-risk list controls.
EUDR timing by role and size: the 30 December 2026 main date, the narrow 30 June 2027 operator exception, its timber exclusion, and the evidence needed to use it.
What supplier evidence to collect for EUDR Article 9 information, geolocation, risk assessment, due diligence statements, and downstream recordkeeping.
EUDR FAQ on competent authority checks, evidence requests, due diligence records, corrective action and penalties for non-compliance.