Search every question across sub-FAQs

Keep enough evidence to show what the reference number points to and who relied on it. The number alone does not prove deforestation-free status, lawful production, or no/negligible risk; those conclusions sit in the due diligence file behind the statement.

A useful record lets a reviewer answer four questions quickly: which EUDR product movement used the reference, who supplied it, which downstream actor received it, and where the underlying due diligence or simplified declaration record is retained.

A DDS reference number is a filing and handoff identifier, not a compliance certificate. The compliance file remains the due diligence statement, simplified declaration where applicable, Article 9 evidence, risk assessment, and any risk mitigation record.

The information system also assigns an associated verification number to each due diligence statement or simplified declaration as a security number for the data. Keep it distinct from the due diligence statement reference number or declaration identifier and use it where the official information-system workflow requires it.

For each in-scope relevant product, collect plot-level geolocation evidence for the land where the relevant commodities in that product were produced, then keep it tied to the due diligence file. The record should show the relevant commodity or product, supplier, production country or area, production date or time range, plot evidence, supporting documentation for deforestation-free and legal production, and the due diligence statement or simplified declaration reference when one exists.

A polygon is not a complete compliance record. The geolocation evidence must remain connected to the product lot, shipment, batch, or consignment that will be placed on the market, made available, or exported. If the same supplier ships mixed material from multiple production plots, the evidence file needs to preserve which plots support which product movement.

Geolocation also has a legal consequence. Article 9 says deforestation or forest degradation on a listed plot automatically disqualifies the relevant commodities and products from that plot. For all commodities, deforestation-free status uses the 31 December 2020 cut-off; wood also must have been harvested without inducing forest degradation after that date.

Supplier evidence should let the operator or downstream reviewer trace the product back to the production plots or establishments and evaluate whether the EUDR conditions are met. A supplier name alone is not enough if it cannot be connected to the land where the commodity was produced and to the specific product movement being reviewed.

For upstream operators, this usually means collecting and retaining the geolocation information and documentation demonstrating deforestation-free and legal production. For downstream operators and traders, the record should also preserve the supplier details and, where the supplier is an operator, the due diligence statement reference number or simplified declaration identifier communicated through the supply chain.

Build the link in both directions. From a product or consignment, a reviewer should be able to identify the supplier evidence and production plots or establishments that support it. From a plot record, a reviewer should be able to see which product lots, consignments, due diligence statements, or simplified declaration identifiers used that evidence.

EUDR due diligence is performed before placing relevant products on the market or exporting them. Operators submit or make available the due diligence statement through the Article 33 information system when due diligence concludes compliance. Downstream operators and traders then rely on supply-chain information, including reference numbers or declaration identifiers where relevant, rather than a disconnected map archive.

Geolocation evidence is one input into the Article 10 risk assessment. The operator uses the collected information and evidence to assess non-compliance risk before placing on the market or exporting. If the risk assessment does not show no or only negligible risk, the operator must not proceed without risk mitigation.

The review should check whether the plot evidence is complete for the product movement, whether supplier evidence supports deforestation-free and legal production, whether the coordinates overlap land deforested after 31 December 2020, whether wood harvesting caused forest degradation after that date, and whether supply-chain complexity or mixing breaks traceability.

Coordinate precision and polygon thresholds come from the Regulation. Portal file formats, upload limits, and validation messages come from the information-system rules and current technical instructions. Record which technical specification was used instead of treating a portal convention as part of Article 2.

The Article 2 definition requires latitude and longitude coordinates with at least six decimal digits. One point can describe a plot of four hectares or less. A non-cattle production plot larger than four hectares requires a polygon with enough points to describe its perimeter. Article 9 requires all production plots when multiple plots contributed to the product.

A plot of land is land within one real-estate property under the law of the production country, with sufficiently homogeneous conditions to evaluate aggregate deforestation and forest-degradation risk. The four-hectare rule applies to each such plot, not to a supplier's total farm area or a shipment's combined sourcing area.

For cattle and products made from or fed with cattle, Article 9 refers to all establishments where the cattle were kept. Eligible micro or small primary operators may replace Article 9(1)(d) geolocation with the postal address of all plots or the establishment. That substitution does not extend to other operators.

Treat the filing as a release gate for in-scope relevant products. Operators must exercise due diligence before placing relevant products on the EU market or exporting them, and they must not place or export the product without prior submission of the due diligence statement. If due diligence supports compliance with Article 3 and shows no or negligible risk, the operator makes the due diligence statement available to competent authorities through the Article 33 information system.

The filing owner should therefore be the role that can confirm the product, supplier, shipment, or export fact pattern is ready for submission. An authorised representative may submit on the operator's behalf, but that handoff does not move compliance responsibility away from the operator.

Annex II defines the legal statement content: operator identity and address; EORI number for products entering or leaving the market; Harmonised System code; free-text product description, trade name and scientific name where applicable; quantity; country of production; geolocation of every production plot or cattle establishment; the prescribed compliance declaration; and signature information.

A submitted EUDR due diligence statement produces a reference number that needs to move with the supply-chain handoff. For the simplified regime, a micro or small primary operator submits a one-time simplified declaration in the Article 33 information system and receives a declaration identifier. Those identifiers let later actors connect their product intake, sale, export, or authority response to the upstream EUDR filing.

Downstream operators and traders should collect supplier details and, where the supplier is an operator, the due diligence statement reference number or declaration identifier. They should also keep downstream recipient details so the evidence trail can show both where the covered product came from and where it went.

Ownership depends on the actor's EUDR role. Operators own the due diligence conclusion and the decision to submit the due diligence statement before placing on the market or exporting. Micro or small primary operators using the simplified route own the simplified declaration and declaration identifier. Non-SME downstream operators and non-SME traders register in the Article 33 information system before placing, making available, or exporting, but Article 5 no longer requires them to submit a new statement for already-covered products.

If an authorised representative submits the statement or simplified declaration, the filing workflow should still show the operator's approval, the representative's authority to act, and the returned reference number or declaration identifier. The source supports representative submission, but it does not support treating the representative as the party that assumes Article 3 compliance responsibility.

Keep evidence that lets a reviewer reconstruct the filing without guessing. The record should show the Article 3 compliance basis, the due diligence conclusion, the submission route used, the filing identifier returned, and the handoff to downstream actors. Operators keep due diligence statement records for five years; downstream operators and traders keep Article 5(3) supply-chain information for at least five years and provide it to competent authorities on request.

For a simplified declaration, retain the Article 2(15a) eligibility analysis and the Annex III data: operator identity, EORI number where applicable, Harmonised System code, product description, one-off estimated annual quantity, country of production, geolocation or permitted postal addresses for all plots or cattle establishments, and the prescribed declaration. Article 4a permits an update following any major changes; record the trigger, revised data, submission result, and continuing eligibility.

Portal screens and technical fields can change under implementing rules. Keep the business and regulatory trail: scope decision, due diligence file, submitted statement or simplified declaration, returned reference number or declaration identifier, representative mandate if used, supplier and recipient records, and any amendment, withdrawal, or authority-response log.

Do not release the product on the basis of an unresolved risk note. The EUDR due diligence sequence is information collection under Article 9, risk assessment under Article 10, and risk mitigation under Article 11 where the risk is not negligible.

An operator must not place the relevant product on the market or export it unless the risk assessment reveals no or only negligible risk of non-compliance. If the assessment remains non-negligible, complete mitigation first and hold release until the evidence supports the required conclusion.

Do not convert this into an unsupported numeric threshold. Article 2 defines negligible risk through a full assessment and no cause for concern about Article 3(a) or 3(b). The Regulation does not provide a universal score, percentage, or supplier rating that automatically permits release.

Article 10 tests collected information against non-compliance risk. The assessment must consider the country benchmark; forests and deforestation prevalence; indigenous peoples' presence, consultation, and reasoned land claims; the reliability and links between Article 9 evidence; supply-chain complexity and processing stage; difficulty connecting products to plots; circumvention or mixing; substantiated concerns; compliance history; and any other relevant information.

Article 11 is triggered when that assessment does not reach no or negligible risk. Mitigation must happen before placement or export. The Regulation gives examples: request additional information, data, or documents; carry out independent surveys or audits; or take other measures tied to Article 9 information. It also allows supplier support, including smallholder capacity building and investment.

After mitigation, the release file should show the updated risk conclusion and why the remaining risk is no or negligible. Article 10 requires the operator to document and review risk assessments at least annually and to show how the evidence was checked against the legal criteria.

For low-risk production, Article 13 removes Articles 10 and 11 only when its conditions are met, including an assessment of supply-chain complexity and circumvention or mixing risks and documentation showing negligible risk of circumvention or mixing. A substantiated concern or other relevant information pointing to non-compliance or circumvention restores the Article 10 and 11 duties and must be communicated immediately to the competent authority.

For operators, stop before placing the relevant product on the market or exporting it when the risk assessment does not show no or only negligible risk. A due diligence statement should follow a supported due diligence conclusion; it should not be used to override an unresolved assessment.

For non-SME downstream operators and non-SME traders, the stop point is also important when information indicates non-compliance before the regulated activity. If there are substantiated concerns, they must verify due diligence and not place, make available, or export unless verification demonstrates no or negligible risk.

This release gate should apply to each affected product movement. A supplier approval, prior shipment, or generic commodity policy does not by itself prove that the current product row has passed the EUDR risk conclusion.

Keep enough evidence for a reviewer to understand both the facts and the conclusion. The EUDR file should connect Article 9 information to the Article 10 result and, where needed, to Article 11 mitigation completed before release.

At minimum, the evidence should identify the relevant commodity or product, the production origin, geolocation or permitted replacement information, documentation supporting deforestation-free status and production under relevant local law, the assessed supply-chain complexity or mixing risk where relevant, and the final risk conclusion. If a due diligence statement is submitted, keep the statement record and communicate the reference number down the supply chain where required.

For downstream operators and traders, keep the supply-chain information needed under Article 5, including supplier details and due diligence statement reference numbers or declaration identifiers when the supplier is an operator. Keep records long enough to satisfy the EUDR five-year recordkeeping requirements reflected in the sources.