EUDR due diligence statement evidence file

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.

Article 9 specifies the intake record. Capture the product description and trade name and, where applicable, scientific name; quantity; country of production; geolocation 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, geolocation evidence, and legality evidence used for that due diligence conclusion. A broad supplier policy or annual sustainability report cannot replace product-linked evidence.

The due diligence statement 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.

Geolocation 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 due diligence statement reference number or declaration identifier.

A DDS evidence file should close with the filing identifiers and retention record. For operators, keep the due diligence statement 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.