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EUDRDDS evidenceEU

EUDR due diligence statement evidence file

This page helps assemble the records that should sit behind an EUDR before a relevant product is placed on the EU market or exported.

It focuses on Article 9 information and evidence, , supplier records, risk assessment and mitigation support, information-system references, and retention.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
5 sections4 primary sources
Overview

Under Regulation (EU) 2023/1115, the EU Deforestation Regulation (EUDR), a is the operator's filing, not the evidence file. Before filing, the operator needs product-linked information that supports the Article 3 conditions and, unless Article 13 simplified due diligence applies, an Article 10 conclusion of no or negligible risk and completed Article 11 mitigation where needed. Keep the product, commodity, production plots or cattle establishments, suppliers, production period, legality and deforestation-free evidence, risk decision, mitigation, and filing reference connected so a reviewer or competent authority can reconstruct the decision. Build this file before covered movements from 30 December 2026. The 30 June 2027 date applies only to operators that were established as natural persons or micro or small undertakings by 31 December 2024, and it does not apply to products covered by the EU Timber Regulation annex.

Section 1

What belongs in the evidence file behind an EUDR due diligence statement?

Start the file with the product and actor facts: the relevant commodity and Annex I product code, the operator, downstream-operator, or trader role, the placing-on-market, making-available, or export event, and whether the product is supported by an operator DDS or a qualifying primary operator's simplified declaration.

Then connect those facts to Article 9 information collection. The record should preserve the information and evidence used to show the product is deforestation-free and legally produced, including plot or establishment location evidence, supply-chain information, and the records provided to competent authorities on request.

  • Product scope record: commodity, derived product, Combined Nomenclature (CN) customs code, company stock-keeping unit (SKU) where used, market event, and actor role.
  • Article 9 information pack: supplier identities, country of production, quantity or batch link, and evidence demonstrating deforestation-free and legal production.
  • record: location data for every production plot or cattle establishment, or the postal-address substitute available only to qualifying micro or small primary operators under Article 4a.
  • DDS filing record: submission, Article 33 information-system reference number, and any simplified declaration identifier passed through the supply chain.
  • Authority-response pack: the version of the evidence file that can be provided to competent authorities when requested.
Recommended next step

Review the evidence behind your EUDR DDS process

This EUDR evidence guide helps check whether Article 9 information, geolocation records, supplier evidence, risk conclusions, DDS references, and retention controls are connected before a statement is filed.

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Section 2

Article 9 information and evidence records

Article 9 specifies the intake record. Capture the product description and trade name and, where applicable, scientific name; quantity; country of production; of every production plot or cattle establishment; production date or time range; supplier and customer details; and adequately conclusive and verifiable information showing deforestation-free and lawful production. Keep the source, reviewer, and version for each item.

Link each product lot or shipment to the supplier evidence, evidence, and legality evidence used for that due diligence conclusion. A broad supplier policy or annual sustainability report cannot replace product-linked evidence.

  • Supplier record: direct supplier, upstream supplier data available to the operator, and the person or team that validated the supplied evidence.
  • Production-location record: country of production, of every plot or cattle establishment, and production date or time range; use the postal-address option only for a qualifying micro or small primary operator.
  • Deforestation-free support: evidence that the commodities were not produced on land subject to deforestation after 31 December 2020 and, for relevant products containing or made using wood, that the wood was harvested without inducing forest degradation after that date.
  • Legal-production support: documents used to show production complied with relevant legislation in the country of production.
  • Evidence availability record: where the Article 9 information is stored and how it can be provided to competent authorities on request.
Section 3

Risk assessment and mitigation evidence

The must not be filed while risk remains unresolved. Unless Article 13 simplified due diligence applies, the evidence file should show the risk assessment conclusion and the facts behind it: whether the assessment found no or only negligible risk of non-compliance, or whether mitigation was required before the product moved.

When risk is not negligible, keep the mitigation evidence with the same product record. The reviewer should see the original concern, the mitigation action, the revised conclusion, and the approval to proceed. If the product is produced in a low-risk country or part of a country, the record should still document the supply-chain complexity and circumvention or mixing checks that support simplified due diligence.

  • Risk assessment memo: product, supplier, production location, evidence reviewed, risk factors considered, and no-or-negligible-risk conclusion.
  • Mitigation log: extra supplier information, independent checks, segregation or chain-of-custody controls, corrective actions, and residual-risk approval.
  • Stop condition: where Article 10 applies, if the risk assessment does not reach no or negligible risk after mitigation, do not file the DDS for that product movement.
  • Low-risk production file: country or part-of-country classification used, supply-chain complexity review, and documentation showing negligible risk of circumvention or mixing.
Section 4

Geolocation and supplier evidence controls

data should be managed as controlled compliance evidence, not as a free-text supplier attachment. The record needs enough structure to show which plots or establishments supplied the relevant product and which DDS or declaration record used that data.

Supplier evidence should also preserve the supply-chain handoff. Downstream operators and traders need the required supply-chain information, including supplier details and, when the supplier is an operator, the reference number or declaration identifier.

  • Link each dataset to the supplier, product batch or shipment, production period used by the company, and evidence version.
  • Record whether the evidence is plot-level or an allowed postal-address substitute for a micro or small primary operator.
  • Keep supplier-provided evidence separate from validation notes so reviewers can see what was received and what was checked.
  • Pass DDS reference numbers or simplified declaration identifiers downstream with the product information rather than burying them in email threads.
  • Flag supplier evidence for escalation when the location, commodity, product identity, or reference number cannot be matched to the shipment.
Section 5

Reference numbers, declaration identifiers, and retention

A DDS evidence file should close with the filing identifiers and retention record. For operators, keep the record for five years and communicate DDS reference numbers to downstream operators and traders. Where the simplified declaration regime applies, keep the declaration identifier instead of treating the simplified filing as an ordinary supplier certificate.

For downstream operators and traders, preserve the Article 5 supply-chain information for at least five years and make it available to competent authorities on request. If new information indicates possible non-compliance, the evidence file should show who was informed and, when Article 5 requires a non-SME downstream operator or non-SME trader to verify a substantiated concern, what verification happened and whether the product was stopped before placement, making available, or export.

  • DDS log fields: product, supplier, operator, Article 33 submission, DDS reference number, evidence-file version, and downstream recipients informed.
  • Simplified declaration fields: micro or small primary operator status check, declaration submission, declaration identifier, and supporting Article 9 substitute data where applicable.
  • Verification number: keep it access-controlled and distinct from the DDS reference number or declaration identifier communicated through the supply chain.
  • Downstream information fields: supplier and business-recipient names, postal and email addresses, and website addresses if available; DDS reference number or declaration identifier when the immediate supplier is an operator; and the authority-response owner.
  • Retention control: five-year record clock for operator DDS records and at-least-five-year retention for Article 5 downstream supply-chain information.
  • New-information control: substantiated concern, non-compliance signal, authority notice, downstream notice, verification result, and placement/export hold decision.
Primary sources

References and citations

Consolidated Regulation (EU) 2023/1115
eur-lex.europa.eu6 citations
Referenced sections
  • Primary source for definitions, the Article 3 conditions, DDS submission, Article 9 information, risk assessment, mitigation, simplified routes, Annex II, and retention.
  • Articles 3, 4, 4a, 5, 8 to 11, and Annex II support the product conditions, actor routes, evidence sequence, and DDS filing record.
  • Article 2 defines deforestation-free and sets the 31 December 2020 cut-off; Article 9 lists the required product, quantity, origin, geolocation, production-time, party, and compliance information.
Show 3 more
  • Articles 8 to 11 support the three-part due-diligence sequence, no-or-negligible-risk release condition, and mitigation of non-negligible risk before placement or export.
  • Articles 4a, 5, and 9 support geolocation or the limited postal-address option, supplier and recipient data, and DDS reference or declaration-identifier handoff.
  • Articles 4 and 5 support five-year operator DDS retention, at-least-five-year downstream supply-chain retention, authority access, and reference-number handoff.
Commission Implementing Regulation (EU) 2026/1565
eur-lex.europa.eu2 citations
Referenced sections
  • Current Information System amendment for DDS and simplified-declaration administration.
  • Current amendment to the Information System rules for DDS records, simplified declarations, and grouped filing references.
European Commission EUDR overview
environment.ec.europa.eu2 citations
Referenced sections
  • Commission overview of the current implementation timetable and EUDR evidence objective.
  • Commission overview of the EUDR product and proof framework and its current application dates.
Regulation (EU) 2025/2650
eur-lex.europa.eu
Referenced sections
  • Amending act for the current micro or small primary-operator, downstream-operator, and trader framework.

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