--- title: "EU Deforestation Regulation FAQ" canonical_url: "https://www.sorena.io/artifacts/eu/deforestation-regulation/faq" source_url: "https://www.sorena.io/artifacts/eu/deforestation-regulation/faq" author: "Sorena AI" description: "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." published_at: "2026-05-09" updated_at: "2026-07-25" keywords: - "EUDR FAQ" - "EU Deforestation Regulation" - "due diligence statement" - "DDS reference number" - "EUDR geolocation" - "EUDR operators" - "EUDR traders" - "EUDR country benchmarking" - "EUDR customs release" - "EUDR records" - "EUDR" - "geolocation" - "operators" - "traders" - "country benchmarking" - "customs release" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EU Deforestation Regulation FAQ 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. *FAQ* *EUDR* *EU* ## EU Deforestation Regulation FAQ scope, evidence, filings, and records Direct answers for teams checking whether products can be placed on the EU market, made available, or exported under the EUDR. The focus is on covered commodities and products, operators and traders, due diligence statements, geolocation, supplier evidence, customs handoff, timing, enforcement, and records. Regulation (EU) 2023/1115 requires in-scope commodities and products to be deforestation-free, produced in accordance with relevant legislation in the country of production, and covered by the required due diligence statement or simplified declaration before they are placed on the EU market, made available, or exported. Core obligations apply from 30 December 2026. The later 30 June 2027 date is limited to certain natural persons and micro or small undertakings established by 31 December 2024 and meeting Article 38's conditions; it is not a general SME extension. ## Definitions ### EUDR due diligence statement **Term:** due diligence statement A due diligence statement is the operator's submission in the Article 33 information system after completing the required due diligence and concluding that a relevant product complies with Article 3 and presents no or only negligible risk of non-compliance. Submission gives the operator responsibility for the compliance conclusion and produces a reference number for supply-chain handling. **Why it matters here:** The statement is a legal filing, not the complete evidence file. Operators retain the supporting product, origin, legality, deforestation-free, risk, and mitigation records and communicate the reference number to downstream operators and traders. Sources: - [Consolidated Regulation (EU) 2023/1115, Articles 4, 8, and 33](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - [Commission Implementing Regulation (EU) 2024/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3084&ref=sorena.io) ## Browse sub-FAQ modules ### [EUDR Annex I product lookup: how to check scope](/artifacts/eu/deforestation-regulation/faq/annex-i-product-lookup.md) 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. - 4 items ### [EUDR country benchmarking FAQ: low, standard, and high risk](/artifacts/eu/deforestation-regulation/faq/country-benchmarking.md) What EUDR country benchmarking means, how low-risk production affects simplified due diligence, and what operators still need to collect. - 4 items ### [EUDR customs and import release FAQ](/artifacts/eu/deforestation-regulation/faq/customs-and-import-release.md) How to prepare EUDR due diligence statement references, information-system handoffs, importer checks, and release evidence before customs or export clearance. - 5 items ### [EUDR DDS Reference Numbers: What to Record and Pass Down](/artifacts/eu/deforestation-regulation/faq/dds-reference-numbers.md) FAQ on EU Deforestation Regulation DDS reference numbers, including operator submissions, downstream handoffs, Article 33 information-system context, and evidence records. - 4 items ### [EUDR geolocation plots and polygons FAQ](/artifacts/eu/deforestation-regulation/faq/geolocation-plots-and-polygons.md) How EUDR teams should collect, link, and use plot-level geolocation evidence for due diligence statements, suppliers, consignments, and risk assessment. - 5 items ### [EUDR information system filing: DDS references and handoffs](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md) FAQ guidance on EUDR information system filing, due diligence statement submission, declaration identifiers, downstream handoffs, representatives, and evidence retention. - 4 items ### [EUDR non-negligible risk: what stops product release?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md) 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. - 5 items ### [EUDR operator, trader, and downstream roles FAQ](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md) Classify EUDR operators, downstream operators, and traders by product and transaction, then identify the due diligence, information, registration, and recordkeeping duties for each role. - 4 items ### [EUDR simplified due diligence: low-risk country evidence FAQ](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md) 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. - 4 items ### [EUDR SME timing: which dates apply to micro, small, and medium businesses?](/artifacts/eu/deforestation-regulation/faq/sme-timing.md) 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. - 4 items ### [EUDR Supplier Evidence FAQ](/artifacts/eu/deforestation-regulation/faq/supplier-evidence.md) What supplier evidence to collect for EUDR Article 9 information, geolocation, risk assessment, due diligence statements, and downstream recordkeeping. - 6 items ### [How is the EU Deforestation Regulation enforced?](/artifacts/eu/deforestation-regulation/faq/enforcement.md) EUDR FAQ on competent authority checks, evidence requests, due diligence records, and official source non-compliance consequences. - 5 items Browse all indexed questions: [/artifacts/eu/deforestation-regulation/faq/items](/artifacts/eu/deforestation-regulation/faq/items.md) ## What products are in scope of the EU Deforestation Regulation? The EUDR applies to relevant commodities and the derived products listed in Annex I. The Regulation covers cattle, cocoa, coffee, oil palm, rubber, soya, and wood as relevant commodities, with listed derived products also in scope. A product is not cleared by commodity name alone. The practical scope check should match the product, commodity input, and Annex I product listing, then confirm whether the activity is placing on the EU market, making available on the market, or export. - Check the commodity or material input first. - Check whether the finished or intermediate product is listed in Annex I. - Keep the product classification, commodity link, supplier, and EUDR role together in the record. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the Article 3 scope rule and Annex I product-listing approach for relevant commodities and products. - [European Commission EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - Supports the public overview of the EUDR's commodity coverage and anti-deforestation purpose. ## What must be true before an EUDR product is placed on the EU market or exported? The product must meet all three Article 3 conditions: it is deforestation-free, it was produced in accordance with relevant legislation of the country of production, and it is covered by a due diligence statement or simplified declaration where required. If due diligence does not show no or only negligible risk, the product should not be placed on the market or exported until risk mitigation has reduced the risk to the required level. - Collect information and evidence under Article 9. - Assess risk under Article 10 unless a supported simplified due diligence route applies. - Mitigate non-negligible risk under Article 11 before market placement or export. - Submit the due diligence statement before placing on the market or exporting. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Summarizes Article 3 and Articles 8 to 11: information collection, risk assessment, risk mitigation, and the no/negligible-risk condition. ## Who is an operator, downstream operator, or trader under the EUDR? An operator places relevant products on the market or exports them. A downstream operator places on the market or exports relevant products made using relevant products already covered by a due diligence statement or simplified declaration. A trader makes relevant products available on the market and is not an operator or downstream operator. Role classification matters because the filing, registration, information-collection, and downstream communication duties differ. Non-SME downstream operators and non-SME traders must register in the EUDR information system before placing, making available, or exporting relevant products. - Assign the role per transaction, not only per company. - Keep supplier details and downstream recipient details for trader and downstream-operator records. - Capture due diligence statement reference numbers or declaration identifiers when supplied by an upstream operator. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the definitions of operator, downstream operator, trader, and the Article 5 information duties. ## What is an EUDR due diligence statement and reference number? A due diligence statement is the operator's submission through the Article 33 information system after due diligence shows compliance and no or only negligible risk. The information system assigns a reference number for the submitted statement. Operators must communicate due diligence statement reference numbers, or simplified declaration identifiers where relevant, to downstream operators and traders further down the supply chain. Those identifiers are not a substitute for checking whether the right product, supplier, batch, and role are covered. - File the due diligence statement before placing on the market or exporting. - Store the reference number with the product, shipment, supplier, and declaration evidence. - Pass the reference number or declaration identifier to downstream actors that need it. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the operator duty to submit due diligence statements and communicate reference numbers or declaration identifiers downstream. - [Commission Implementing Regulation (EU) 2024/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3084&ref=sorena.io) - Supports the EUDR information-system context for due diligence statement handling. ## What geolocation evidence does the EUDR require? Article 9 information collection includes geolocation of the plots of land or establishments connected to the relevant commodity or product, plus evidence showing deforestation-free status and legal production. For micro or small primary operators, the Regulation includes a limited replacement: the Article 9 geolocation may be replaced by the postal address of plots of land or the establishment. That exception should be applied only after confirming the actor meets the micro or small primary-operator conditions. - Keep geolocation with the supplier, commodity, product, and production evidence. - Preserve documentation showing deforestation-free and legal production. - Record any micro or small primary-operator postal-address substitution separately from the standard geolocation workflow. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports Article 9 geolocation and evidence requirements, including the limited micro or small primary-operator substitution. *Recommended next step* *Placement: after records section* ## Build the EUDR evidence file before release Use the FAQ answers to connect each in-scope product to its commodity, role, supplier evidence, geolocation, risk assessment, due diligence statement, customs handoff, and five-year record. - [Open Research Copilot](/solutions/research-copilot.md): Check EUDR questions against cited official source material. - [Discuss EUDR implementation](/contact.md): Review product scope, supplier evidence, and filing records with Sorena. ## How does EUDR country benchmarking affect due diligence? Commission Implementing Regulation (EU) 2025/1093 provides the current country list: countries named in its Annex take the listed low- or high-risk tier, while unlisted countries remain standard risk. Retain the implementing-act version and date checked because Article 29 benchmarking can change. Low-risk production does not remove all EUDR work. Operators using simplified due diligence for low-risk production still need to assess supply-chain complexity and risks of circumvention or mixing, and they must be able to provide documentation showing negligible risk of circumvention or mixing. - Do not treat a low-risk country as a blanket exemption. - Keep evidence that the relevant product was produced in the low-risk country or part of a country. - Document the supply-chain complexity and mixing or circumvention checks before relying on simplified due diligence. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the Article 13 simplified due diligence conditions, the Article 29 country benchmarking system, the initial standard-risk assignment, and the requirement to publish and update low- and high-risk lists. - [Commission Implementing Regulation (EU) 2025/1093](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32025R1093&ref=sorena.io) - Current implementing act for the low- and high-risk country list; countries not listed in either category remain standard risk. ## What supplier evidence should buyers collect for EUDR compliance? Supplier evidence should prove the Article 3 conditions for the specific product and supply chain. That means supplier identity, product and commodity linkage, country and place of production, geolocation or permitted substitute, legal-production documentation, deforestation-free evidence, and any due diligence statement reference number or declaration identifier received from an upstream actor. Downstream operators and traders also need enough information to identify their supplier and downstream recipients, keep the information for at least five years, and provide it to competent authorities upon request. - Supplier name, address, and role. - Relevant commodity and Annex I product classification. - Geolocation, production-location evidence, or permitted postal-address substitute. - Legal-production and deforestation-free documentation. - Due diligence statement reference number or declaration identifier where the supplier is an operator. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports Article 5 supply-chain information duties and Article 9 information and evidence collection. ## Can customs or logistics release an EUDR import without the filing evidence? As an internal release control, no: if the product is in EUDR scope and the transaction requires an operator filing, the customs or logistics workflow should not move ahead without the due diligence statement reference number or applicable declaration identifier tied to that product and movement. This control does not describe every customs authority's procedure or decide whether a particular declaration will be accepted. The Regulation supports the core dependency: operators must submit the required statement before placing on the market or exporting, and reference numbers or declaration identifiers must travel downstream. Treat the identifier as a release gate, not as an after-the-fact cleanup item. - Match the reference number or declaration identifier to the product, shipment, and operator. - Escalate missing, mismatched, or stale identifiers before release or export steps continue. - Keep the customs handoff record with the EUDR due diligence file. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the pre-market and pre-export filing requirement and the downstream communication of reference numbers or declaration identifiers. - [Commission Implementing Regulation (EU) 2024/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3084&ref=sorena.io) - Supports the information-system context used for EUDR due diligence statement handling. ## What EUDR timing applies to SMEs and smaller actors? The high-level Commission overview and consolidated Regulation identify 30 December 2026 as the main EUDR application date and 30 June 2027 as the later date for certain operators. The consolidated Regulation narrows that later date to operators that are natural persons or micro or small undertakings established as such by 31 December 2024, except for products covered by the Annex to the EU Timber Regulation. Do not apply the later date merely because an entity calls itself an SME. Confirm the actor type, establishment date, size category, product role, and any specific conditions before relying on the later application date. - Record whether the actor is a natural person, micro undertaking, small undertaking, medium undertaking, or larger entity. - Record whether the undertaking was established by 31 December 2024 if relying on the later date. - Keep timing assumptions separate from product-scope and role-classification evidence. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the main application date and the later date for certain natural persons and micro and small undertakings established by 31 December 2024. - [European Commission EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - Supports the public high-level timing summary for the main and later EUDR application dates. ## What changes for micro or small primary operators under the EUDR? A micro or small primary operator is a natural person or micro or small undertaking established in a low-risk country that places on the market or exports relevant products it has itself grown, harvested, obtained from, or raised. For that actor, certain Article 4 obligations do not apply. Instead, the Regulation describes a one-time simplified declaration in the Article 33 information system before placing on the market or exporting, after which the operator receives a declaration identifier. - Confirm the actor is actually a micro or small primary operator. - Submit the simplified declaration before placing on the market or exporting. - Keep the declaration identifier and communicate it where downstream actors need it. - Use postal address substitution for geolocation only where the stated conditions apply. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the micro or small primary-operator definition, simplified declaration route, declaration identifier, and geolocation substitute. ## What happens if an EUDR risk or non-compliance concern appears after products move? Downstream operators and traders that obtain relevant new information indicating that a product they placed or made available is at risk of non-compliance must inform competent authorities and downstream recipients. For exports, downstream operators inform the competent authority of the Member State that is the country of production. Before placing, making available, or exporting, non-SME downstream operators and non-SME traders that receive information indicating non-compliance must inform competent authorities. For substantiated concerns, they verify due diligence and do not proceed unless verification demonstrates no or negligible risk. - Escalate new risk information instead of waiting for the next periodic review. - Notify competent authorities and downstream recipients where the Article 5 conditions are triggered. - Hold products where verification does not demonstrate no or negligible risk. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports Article 5 duties to inform authorities and downstream recipients when new risk or non-compliance information appears. ## What EUDR records should teams keep, and for how long? Operators keep a record of due diligence statements for five years. Downstream operators and traders keep Article 5 supply-chain information for at least five years and provide it to competent authorities upon request. A useful EUDR record should connect the scope decision, product classification, role classification, supplier evidence, geolocation or permitted substitute, legal-production evidence, deforestation-free evidence, risk assessment, mitigation record where needed, due diligence statement reference number or declaration identifier, and downstream communication record. - Due diligence statements and reference numbers. - Supplier, operator, trader, and downstream recipient information. - Geolocation, country, production, legal, and deforestation-free evidence. - Risk assessment and mitigation evidence where required. - Authority requests, responses, and new-risk notifications. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the five-year operator statement record and the at-least-five-year Article 5 information retention duty. ## What penalties and corrective action can follow EUDR non-compliance? Article 24 allows competent authorities to require corrective action such as correcting formal failures, preventing placement or export, withdrawal or recall, donation where appropriate, or disposal. Article 25 requires Member States to establish effective, proportionate, and dissuasive penalties, including fines and other listed sanctions. For a legal person, the maximum fine available under national rules must be at least 4% of the total annual Union-wide turnover in the financial year preceding the fining decision and may need to exceed the economic benefit gained. The exact penalty, procedure, and available remedies depend on the applicable Member State rules and the case facts. - Use Article 24 to distinguish corrective action from penalties. - Use Article 25 for the required penalty categories and the legal-person maximum-fine floor. - Check current Member State law for the exact procedure and sanction that can be imposed. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports Article 24 corrective action, Article 25 penalty categories, and the legal-person maximum-fine floor. ## Primary sources - [Consolidated Regulation (EU) 2023/1115](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Primary EUDR legal text for scope, Article 3 conditions, actor definitions, due diligence, geolocation, reference numbers, country benchmarking, application dates, customs controls, corrective action, penalties, notifications, and recordkeeping. - [Commission Implementing Regulation (EU) 2024/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3084&ref=sorena.io) - Official implementing regulation source for the EUDR information system used for due diligence statements and related operational handling. - Quote: "Information System" - [European Commission EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - Commission overview source used for high-level EUDR purpose, commodity context, and application-date overview. - Quote: "deforestation-free products" - [Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2650&ref=sorena.io) - Amending regulation source used to confirm that the consolidated EUDR text reflects later operator and trader obligation changes. - Quote: "amending Regulation (EU) 2023/1115" --- [Privacy Policy](https://www.sorena.io/privacy.md) | [Terms of Use](https://www.sorena.io/terms-of-use.md) | [DMCA](https://www.sorena.io/dmca.md) | [About Us](https://www.sorena.io/about-us.md) (c) 2026 Sorena AB (559573-7338). 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