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 practical review should check whether the plot evidence is complete for the product movement, whether supplier evidence supports deforestation-free and legal production, whether there is supply-chain complexity or possible mixing that could break traceability, and whether any new information indicates a risk of non-compliance.
Flag missing plot evidence, mismatched supplier data, or product lots that cannot be tied back to production evidence.
Check whether the country or area risk treatment used in the file matches the EUDR benchmarking and simplified-due-diligence rules grounded for the product.
Escalate mixed or complex supply chains where the geolocation file does not show which plots support the specific product movement.
Document the risk conclusion and any mitigation before shipment, market placement, or export approval.
Are there grounded exceptions or limits for geolocation evidence?
The available grounding supports one specific adjustment: for micro or small primary operators, Article 9(1)(d) geolocation may be replaced by the postal address of the plots of land or the establishment. That does not remove the need to keep the product, supplier, and due diligence evidence coherent.
The grounding reviewed for this FAQ does not support a public claim about a particular coordinate format, polygon file format, or plot-size threshold. If a workflow needs those details, treat them as blocked until the exact source text, implementing guidance, or system specification is available and cited.
Apply the postal-address substitute only to the grounded micro or small primary-operator fact pattern.
Do not generalize that substitute to ordinary operators, downstream operators, or traders without source support.
Do not add polygon thresholds, coordinate precision rules, or file-format requirements to public guidance unless the cited source states them.
When supplier data is incomplete, record the gap as unresolved risk instead of treating a partial map file as sufficient evidence.
EUDR information system filing: DDS references and handoffs
What should teams do about EUDR information system filing?
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. A representative may submit on the operator's behalf, but that handoff should not move the compliance responsibility away from the operator.
Before filing: confirm the relevant commodity or product is in scope, the due diligence file is complete, and risk is no or negligible.
At filing: submit the due diligence statement through the Article 33 information system, or use the simplified declaration route only where the micro or small primary-operator conditions apply.
After filing: store the due diligence statement record and communicate the reference number or declaration identifier to downstream operators and traders further down the supply chain.
Supports the filing gate: products must be covered by a due diligence statement or simplified declaration, operators submit before placing or export, and representatives may submit while the operator retains responsibility.
EUDR information system filing: DDS references and handoffs
How should teams handle EUDR reference numbers and declaration identifiers?
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 simplified declaration in the Article 33 information system and receives a declaration identifier. Those identifiers are not decorative metadata; they are how later actors can 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.
Record the supplier, product, shipment or batch context, and the due diligence statement reference number or declaration identifier received.
Do not substitute a purchase order, supplier certificate, or internal ticket number for the EUDR filing reference or declaration identifier.
Keep the identifier available for competent-authority requests and for downstream recipients that need the filing link.
Supports the distinction between due diligence statement reference numbers and simplified-declaration identifiers, and the requirement to communicate or retain them in the supply chain.
EUDR information system filing: DDS references and handoffs
Who owns the EUDR information system handoff?
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 have their own registration step in the Article 33 information system before placing, making available, or exporting.
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 grounding source supports representative submission, but it does not support treating the representative as the party that assumes Article 3 compliance responsibility.
Operator: approves the due diligence conclusion, submits or authorizes submission, retains the statement record, and passes the identifier downstream.
Authorised representative: may submit the statement or simplified declaration on behalf of the operator, with the mandate and submission result retained in the evidence file.
Downstream operator or trader: collects supplier and recipient information, keeps the required identifiers, and registers in the Article 33 system where the non-SME rule applies.
Supports role-specific filing responsibility, downstream and trader information duties, non-SME registration, and authorised-representative submission without shifting operator responsibility.
EUDR information system filing: DDS references and handoffs
What audit evidence should teams retain for EUDR filing?
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.
Avoid unsupported assumptions about portal screens or field names. The durable evidence is 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 authority-response log.
Scope and role memo showing whether the actor is an operator, micro or small primary operator, downstream operator, or trader for the product flow.
Due diligence evidence supporting deforestation-free status, relevant production-country legality, risk assessment, and mitigation where needed.
Submitted due diligence statement record or simplified declaration record, including the reference number or declaration identifier.
Representative mandate and submission confirmation where an authorised representative files on behalf of the operator.
Supplier, downstream recipient, and identifier handoff records retained for the required five-year evidence period.
Supports the due diligence evidence set, the five-year statement and supply-chain information retention duties, and the need to provide records to competent authorities on request.
EUDR non-negligible risk: what stops product release?
What should teams do about non-negligible risk under the EU Deforestation Regulation?
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.
For an operator, the practical consequence is direct: do 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, the file needs mitigation first, and the release decision should wait until the evidence supports the required conclusion.
Do not convert this into an unsupported numeric threshold. The grounding sources support a legal conclusion of no/negligible risk versus risk that is not negligible; they do not provide a universal risk score, percentage, or supplier rating that automatically permits release.
Classify the actor first: operator release decisions focus on placement on the market or export; downstream operator and trader duties can also involve making products available.
Tie the risk conclusion to product rows, origin facts, supplier evidence, and the required due diligence statement or simplified declaration path.
If the conclusion is not no or negligible risk, hold placement or export until Article 11 mitigation is completed and reassessed.
EUDR non-negligible risk: what stops product release?
How do Article 10 assessment and Article 11 mitigation work together?
Article 10 is the point where collected information is tested against non-compliance risk. A useful record should show the product and commodity in scope, the production origin, the geolocation or permitted replacement information, and documentation supporting deforestation-free and lawful production.
Article 11 is triggered when that assessment does not reach no or negligible risk. Mitigation is not a promise to fix the file later; it is work that must happen before the operator places the product on the market or exports it. After mitigation, the release file should show the updated risk conclusion and why the remaining risk is no or negligible.
For low-risk production, do not skip all risk thinking. The simplified route removes Articles 10 and 11 only where the Article 13 conditions are met, including an assessment of supply-chain complexity and risks of circumvention or mixing, plus documentation showing negligible risk of circumvention or mixing.
Article 10 output: a documented conclusion that the product presents no or only negligible risk, or that mitigation is required.
Article 11 output: mitigation evidence and a reassessed conclusion before placement on the market or export.
Low-risk simplification output: documentation showing negligible risk of circumvention or mixing, not merely a country label.
EUDR non-negligible risk: what stops product release?
When should product release stop because of non-negligible risk?
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 should 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.
Stop before operator placement or export when Article 10 still shows non-negligible risk.
Stop before downstream placement, availability, or export when substantiated concerns have not been verified to no or negligible risk.
Resume only when mitigation or verification evidence supports the no/negligible-risk conclusion for the affected product movement.
Supports distinguishing operator, downstream operator, and trader release responsibilities when non-compliance information or substantiated concerns exist.
EUDR non-negligible risk: what stops product release?
What evidence should support a no/negligible-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 grounding sources.
Article 9 evidence: origin, geolocation or permitted replacement information, and documentation for deforestation-free and lawful production.
Article 10 evidence: risk assessment conclusion and the facts considered for that product movement.
Article 11 evidence: mitigation actions, updated review, and release approval only after no/negligible risk is supported.
Statement evidence: due diligence statement record, reference number, or simplified declaration identifier where applicable.
EUDR non-negligible risk: what stops product release?
What should teams avoid when documenting non-negligible risk?
Avoid treating non-negligible risk as a business preference or procurement score. The EUDR release condition is a legal due diligence conclusion: no or only negligible risk of non-compliance before the relevant product is placed on the market or exported.
Avoid filing or relying on a due diligence statement while the underlying evidence still says the risk is unresolved. The statement record should sit behind a traceable due diligence file, not substitute for one.
Avoid adding thresholds, grace periods, penalties, or country-score rules unless they are supported by the current source material. For this FAQ, the grounding supports the risk-assessment and mitigation gate, evidence and recordkeeping duties, downstream substantiated-concern handling, and low-risk simplification conditions; it does not support a universal numeric risk score.
Do not release against an unresolved Article 10 finding.
Do not call a mitigation plan complete until the reassessed result supports no or negligible risk.
Do not publish unsupported risk thresholds, supplier scores, or penalty figures on this FAQ page.
Supports the warning against unsupported thresholds by grounding the page in the no/negligible-risk release condition and required mitigation when risk is not negligible.
How should a company classify itself as an EUDR operator, trader, or downstream operator?
Start with the transaction for the relevant product listed in Annex I. If the entity places that relevant product on the EU market for the first time or exports it, it is generally acting as an operator unless the specific downstream-operator definition applies. If it places on the market or exports a relevant product made using relevant products already covered by a due diligence statement or simplified declaration, classify that activity as downstream-operator activity.
If the entity only supplies, distributes, or otherwise makes a relevant product available on the EU market and is not the operator or downstream operator for that product, classify that activity as trader activity. One legal entity can have different EUDR roles for different product flows, so the useful record is product-by-product and transaction-by-transaction.
Operator activity: placing a relevant product on the EU market or exporting it, excluding downstream-operator activity.
Downstream-operator activity: placing on the market or exporting a relevant product made using relevant products already covered by a DDS or simplified declaration.
Trader activity: making a relevant product available on the EU market while not acting as the operator or downstream operator.
Keep role classification tied to the product code, supplier, transaction, market action, and DDS or declaration reference available for that flow.
Defines operator, downstream operator, trader, placing on the market, making available on the market, and exporting as the role-classification anchors.
Confirms the high-level EUDR framing that operators or traders placing covered commodities on, or exporting them from, the EU market must be able to prove compliance.
What changes when the role is operator rather than trader under EUDR?
The operator role carries the core due-diligence obligation before placing relevant products on the EU market or exporting them. Operators must exercise due diligence to prove the Article 3 conditions, submit the due diligence statement through the EUDR information system when the risk is no or negligible, and communicate DDS reference numbers or simplified-declaration identifiers further down the supply chain.
Trader and downstream roles are not a blank pass. Article 5 duties require downstream operators and traders to possess and keep supply-chain information, including supplier details and the DDS reference number or declaration identifier when the supplier is an operator. They must also keep downstream recipient details where applicable and provide the information to competent authorities on request.
Operator file: due diligence information, risk assessment, risk mitigation where needed, submitted DDS, and DDS record.
Downstream or trader file: supplier identity, operator DDS reference number or declaration identifier, customer or downstream recipient details, and authority-response trail.
Handoff control: do not treat a supplier claim as enough if the required DDS reference number or declaration identifier is missing.
Authorised representatives may submit statements or simplified declarations for operators, but the operator retains responsibility for EUDR compliance.
Can downstream operators and traders rely on an upstream due diligence statement?
They can use upstream DDS references as part of the Article 5 information file, but reliance has limits. The downstream operator or trader still needs the required supplier and downstream-recipient information, must retain it, and must provide it to competent authorities on request.
If new information indicates that a product already placed or made available may be at risk of non-compliance, downstream operators and traders must inform competent authorities and downstream recipients. For exports, the EUDR source states that downstream operators inform the competent authority of the Member State that is the country of production. Non-SME downstream operators and non-SME traders have an additional pre-transaction control: where information indicates non-compliance or substantiated concerns exist before placing, making available, or exporting, they must verify due diligence and not proceed unless verification shows no or negligible risk.
Accept an upstream DDS only with the reference number or declaration identifier and supplier details needed for the Article 5 file.
Escalate new risk information instead of passing the product onward on the strength of an old reference.
For non-SME downstream operators and non-SME traders, add a stop gate for substantiated concerns until due diligence verification shows no or negligible risk.
Do not apply non-SME duties to every SME scenario unless the grounded source states that duty for the role and size category.
Which EUDR role records should be retained for operators, traders, and downstream operators?
Keep records that prove why the role was chosen and how the EUDR handoff worked. Operators need the due-diligence file and due diligence statement record. The EUDR source states that operators keep due diligence statement records for five years and communicate DDS reference numbers or declaration identifiers to downstream operators and traders further down the supply chain.
Downstream operators and traders should keep the Article 5 information file for at least five years: supplier details, DDS reference numbers or declaration identifiers where the supplier is an operator, downstream recipient details, notices sent to authorities or downstream recipients, and any verification performed when risk information or substantiated concerns appeared.
Role-classification record for each relevant product flow, including whether the activity is placing, making available, exporting, or downstream manufacturing.
Operator due-diligence pack: Article 9 information and evidence, risk assessment, mitigation record if used, DDS submission, and DDS reference number.
Downstream and trader information pack: supplier details, DDS reference number or declaration identifier, downstream recipient details, and authority-response records.
Reliance-limit record: risk information received, substantiated-concern review, due-diligence verification outcome, and hold-or-release decision for non-SME downstream operators and non-SME traders.
EUDR simplified due diligence: low-risk country evidence
What does EUDR simplified due diligence change?
Simplified due diligence changes only part of the EUDR due diligence system. Where relevant products are produced in a country or part classified as low risk under the Article 29 benchmarking system, operators are not required to carry out Article 10 risk assessment or Article 11 risk mitigation for that low-risk production, provided the Article 13 conditions are met.
The operator still needs to know the product, commodity, production origin, supplier chain, and EUDR role well enough to justify the simplified treatment. A low-risk benchmark is not a blanket exemption from Article 3, Article 4, Article 8, Article 9, or due diligence statement responsibility.
Use simplified due diligence only for production in a country or part that the Commission has classified as low risk under Article 29.
Keep Article 9 information and evidence; simplified due diligence does not erase the information-collection step.
Do not use the simplified route if supply-chain complexity, circumvention risk, or mixing with unknown or higher-risk origin cannot be shown to be negligible.
Supports the Article 13 rule that low-risk-country production can remove Articles 10 and 11 only when the operator satisfies the simplified due diligence conditions.
EUDR simplified due diligence: low-risk country evidence
What information must still be collected?
Article 13 simplified due diligence does not supersede Article 9. Operators still collect and keep the information and evidence needed to show the relevant product is deforestation-free, produced in accordance with the relevant legislation of the country of production, and traceable to the production origin required by the Regulation.
For downstream operators and traders, the record set also needs to preserve the Article 5 supply-chain information they must possess and keep, including supplier details and the due diligence statement reference number or simplified declaration identifier where the supplier is an operator.
Product and commodity scope: relevant product, relevant commodity, quantity, and market or export activity.
Origin evidence: production country or part, and geolocation or permitted establishment information required for the product and actor.
Legality and deforestation-free evidence: documentation showing production met EUDR Article 3 conditions.
Supply-chain records: supplier and downstream recipient details, plus EUDR statement reference numbers or declaration identifiers when required.
EUDR simplified due diligence: low-risk country evidence
When is simplified due diligence unavailable?
Simplified due diligence is unavailable when the product is not produced in a country or part classified as low risk, when the operator cannot ascertain that production occurred in the low-risk area, or when the supply chain creates more than negligible risk of circumvention or mixing with products of unknown, standard-risk, or high-risk origin.
In those cases, the operator should treat the product under the ordinary due diligence route: collect Article 9 information, perform Article 10 risk assessment, and apply Article 11 risk mitigation before placing the product on the EU market or exporting it.
Origin cannot be tied to the low-risk country or part used for the simplified due diligence claim.
Supplier records do not prove that relevant products were not mixed with material from other origins.
Supply-chain complexity leaves a non-negligible risk of circumvention or mixing.
The country or part is standard risk or high risk under the current Article 29 benchmark.
EUDR simplified due diligence: low-risk country evidence
How should teams monitor changes and keep evidence?
Because simplified due diligence depends on the Article 29 benchmark and on the facts of the supply chain, teams should review the simplification before each sourcing route, supplier change, origin change, or benchmark-status change. The record should show the current country-risk basis and the product-specific facts that support it.
Keep evidence in a form that can be produced to competent authorities on request. For operators, that means Article 9 information, the due diligence statement record, and the Article 13 documentation showing negligible circumvention or mixing risk. For downstream operators and traders, keep the Article 5 supply-chain information for the required retention period.
Save the benchmark source checked, the date checked, and the country or part used for the low-risk assessment.
Keep the product-origin file that links the shipment, batch, plot, establishment, or supplier record to the low-risk area.
Keep the circumvention and mixing assessment, including any controls used to prevent substitution or commingling.
Escalate to ordinary due diligence when monitoring shows the benchmark, origin, supplier, or mixing facts no longer support Article 13.
EUDR SME timing: which dates apply to micro, small, and medium businesses?
What should teams do about SME timing under the EU Deforestation Regulation?
Start with the main EUDR date: the core obligations apply from 30 December 2026. The later 30 June 2027 date is narrower: the grounding supports it for certain natural persons and micro or small undertakings established by 31 December 2024, subject to the Regulation's conditions.
Do not roll medium-sized enterprises into the later micro and small undertaking date unless a cited source for the specific fact pattern supports it. For planning, treat medium enterprises as part of the main 30 December 2026 readiness track, then document any narrower exception separately.
Classify the legal actor first: operator, downstream operator, or trader.
Record whether the entity is micro, small, medium, or not an SME, and keep the evidence used for that classification.
For a claimed 30 June 2027 timing position, record the establishment condition, the micro or small status, and the exact EUDR role or activity that supports the later date.
Keep product coverage separate from size status: cattle, cocoa, coffee, oil palm, rubber, soya, wood, and listed derived products still need a product-scope check.
Supports the main 30 December 2026 application date and the later 30 June 2027 date for certain natural persons and micro or small undertakings established by 31 December 2024.