--- 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/items/page/2" 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: "2026-05-09" 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. ## 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) How to classify EUDR operators, downstream operators, and traders, including market-placement triggers, DDS reference handoffs, non-SME duties, and evidence records. - 4 items ### [EUDR simplified due diligence: low-risk country evidence FAQ](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md) FAQ answer on when EUDR simplified due diligence applies, what Article 9 information remains required, when Articles 10 and 11 return, and what records to keep. - 4 items ### [EUDR SME timing: which dates apply to micro, small, and medium businesses?](/artifacts/eu/deforestation-regulation/faq/sme-timing.md) FAQ on EUDR SME timing, including the 30 December 2026 main application date, the 30 June 2027 later date for certain micro and small undertakings, and first evidence records to prepare. - 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 grounded non-compliance consequences. - 4 items Browse all indexed questions: [/artifacts/eu/deforestation-regulation/faq/items](/artifacts/eu/deforestation-regulation/faq/items.md) ## All FAQ items *Page 2 of 3. Showing 20 of 53 items.* ### [How is geolocation used in EUDR risk assessment?](/artifacts/eu/deforestation-regulation/faq/geolocation-plots-and-polygons.md#how-is-geolocation-used-in-eudr-risk-assessment) *Module: [EUDR geolocation plots and polygons](/artifacts/eu/deforestation-regulation/faq/geolocation-plots-and-polygons.md)* 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. - 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. Sources for this answer: - [Regulation (EU) 2023/1115 key due diligence obligations](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports using geolocation and supporting documentation as evidence for Article 10 risk assessment. - [European Commission EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - Provides the Commission overview source for the EUDR policy context and application timing. ### [Are there grounded exceptions or limits for geolocation evidence?](/artifacts/eu/deforestation-regulation/faq/geolocation-plots-and-polygons.md#are-there-grounded-exceptions-or-limits-for-geolocation-evidence) *Module: [EUDR geolocation plots and polygons](/artifacts/eu/deforestation-regulation/faq/geolocation-plots-and-polygons.md)* 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. - 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. Sources for this answer: - [Regulation (EU) 2023/1115 key due diligence obligations](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the specific postal-address substitute for micro or small primary operators and no broader geolocation exception. ### [What should teams do about EUDR information system filing?](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md#what-should-teams-do-about-eudr-information-system-filing) *Module: [EUDR information system filing: DDS references and handoffs](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md)* 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. - 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. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115, Articles 3, 4, 4a, 6 and 33](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - 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. - [Commission Implementing Regulation (EU) 2024/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3084&ref=sorena.io) - Identifies the Commission implementing regulation dedicated to the EUDR information system. ### [How should teams handle EUDR reference numbers and declaration identifiers?](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md#how-should-teams-handle-eudr-reference-numbers-and-declaration-identifiers) *Module: [EUDR information system filing: DDS references and handoffs](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md)* 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. - 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. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115, Articles 4, 4a and 5](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - 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. ### [Who owns the EUDR information system handoff?](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md#who-owns-the-eudr-information-system-handoff) *Module: [EUDR information system filing: DDS references and handoffs](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md)* 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. - 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. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115, Articles 4, 5 and 6](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports role-specific filing responsibility, downstream and trader information duties, non-SME registration, and authorised-representative submission without shifting operator responsibility. ### [What audit evidence should teams retain for EUDR filing?](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md#what-audit-evidence-should-teams-retain-for-eudr-filing) *Module: [EUDR information system filing: DDS references and handoffs](/artifacts/eu/deforestation-regulation/faq/information-system-filing.md)* 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. - 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. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115, Articles 4, 5, 8 to 11 and 13](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - 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. ### [What should teams do about non-negligible risk under the EU Deforestation Regulation?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md#what-should-teams-do-about-non-negligible-risk-under-the-eu-deforestation-regulation) *Module: [EUDR non-negligible risk: what stops product release?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md)* 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. - 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. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115, Articles 8 to 11](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the EUDR due diligence sequence and the release rule that operators proceed only when risk assessment shows no or only negligible risk. - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Summarizes the Article 9, 10, and 11 due diligence steps used to ground this FAQ's non-negligible-risk release gate. ### [How do Article 10 assessment and Article 11 mitigation work together?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md#how-do-article-10-assessment-and-article-11-mitigation-work-together) *Module: [EUDR non-negligible risk: what stops product release?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md)* 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 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. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115, Articles 10, 11, and 13](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports when operators must assess risk, when they must mitigate non-negligible risk, and the limited low-risk production simplification. - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the evidence expectations for Article 9 information, Article 10 risk conclusions, Article 11 mitigation, and low-risk circumvention or mixing documentation. ### [When should product release stop because of non-negligible risk?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md#when-should-product-release-stop-because-of-non-negligible-risk) *Module: [EUDR non-negligible risk: what stops product release?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md)* 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. - 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. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115, Articles 4, 5, 10, and 11](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports the operator release gate, due diligence statement timing, and downstream actor hold point for substantiated concerns. - [EUDR key due diligence articles](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports distinguishing operator, downstream operator, and trader release responsibilities when non-compliance information or substantiated concerns exist. ### [What evidence should support a no/negligible-risk conclusion?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md#what-evidence-should-support-a-nonegligible-risk-conclusion) *Module: [EUDR non-negligible risk: what stops product release?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md)* 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. - 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. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115, Articles 4, 5, 9, and 33](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Supports due diligence statement records, downstream supply-chain information, Article 9 evidence collection, and five-year retention points. - [European Commission EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - Supports the page's high-level EUDR context: the regulation concerns deforestation-free products and the Commission's implementation overview. ### [What should teams avoid when documenting non-negligible risk?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md#what-should-teams-avoid-when-documenting-non-negligible-risk) *Module: [EUDR non-negligible risk: what stops product release?](/artifacts/eu/deforestation-regulation/faq/non-negligible-risk.md)* 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. - 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. Sources for this answer: - [Consolidated Regulation (EU) 2023/1115, Articles 10 and 11](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - 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?](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md#how-should-a-company-classify-itself-as-an-eudr-operator-trader-or-downstream-operator) *Module: [EUDR operator, trader, and downstream roles](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md)* 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. - 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. 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) - Defines operator, downstream operator, trader, placing on the market, making available on the market, and exporting as the role-classification anchors. - [European Commission EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - 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?](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md#what-changes-when-the-role-is-operator-rather-than-trader-under-eudr) *Module: [EUDR operator, trader, and downstream roles](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md)* 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. - 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. 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 distinction between operator due diligence, downstream and trader supply-chain information duties, and DDS reference-number handoffs. - [Commission Implementing Regulation (EU) 2024/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3084&ref=sorena.io) - Supports the reference to the EUDR information system used for due diligence statements. ### [Can downstream operators and traders rely on an upstream due diligence statement?](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md#can-downstream-operators-and-traders-rely-on-an-upstream-due-diligence-statement) *Module: [EUDR operator, trader, and downstream roles](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md)* 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. - 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. 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 limits on downstream and trader reliance, including Article 5 information possession, authority notices, and non-SME verification duties. ### [Which EUDR role records should be retained for operators, traders, and downstream operators?](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md#which-eudr-role-records-should-be-retained-for-operators-traders-and-downstream-operators) *Module: [EUDR operator, trader, and downstream roles](/artifacts/eu/deforestation-regulation/faq/operator-trader-and-downstream-roles.md)* 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. - 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. 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 five-year retention for operator DDS records and Article 5 information retained by downstream operators and traders. ### [What does EUDR simplified due diligence change?](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md#what-does-eudr-simplified-due-diligence-change) *Module: [EUDR simplified due diligence: low-risk country evidence](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md)* 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. - 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. 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 rule that low-risk-country production can remove Articles 10 and 11 only when the operator satisfies the simplified due diligence conditions. - [European Commission EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - Supports the country-risk benchmarking context that separates low-, standard-, and high-risk country classifications. ### [What information must still be collected?](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md#what-information-must-still-be-collected) *Module: [EUDR simplified due diligence: low-risk country evidence](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md)* 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. - 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. 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 downstream operator and trader recordkeeping point for supplier information, statement references, and retention. ### [When is simplified due diligence unavailable?](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md#when-is-simplified-due-diligence-unavailable) *Module: [EUDR simplified due diligence: low-risk country evidence](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md)* 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. - 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. 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 need to document negligible circumvention or mixing risk before relying on simplified due diligence. ### [How should teams monitor changes and keep evidence?](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md#how-should-teams-monitor-changes-and-keep-evidence) *Module: [EUDR simplified due diligence: low-risk country evidence](/artifacts/eu/deforestation-regulation/faq/simplified-due-diligence.md)* 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. - 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. 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 29 benchmarking dependency that teams must monitor before relying on simplified due diligence. - [European Commission EUDR overview](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - Supports the practical point that the Commission country-risk system is the external benchmark for simplified due diligence eligibility. ### [What should teams do about SME timing under the EU Deforestation Regulation?](/artifacts/eu/deforestation-regulation/faq/sme-timing.md#what-should-teams-do-about-sme-timing-under-the-eu-deforestation-regulation) *Module: [EUDR SME timing: which dates apply to micro, small, and medium businesses?](/artifacts/eu/deforestation-regulation/faq/sme-timing.md)* 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. - 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. 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 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. - [Regulation (EU) 2025/2650 amending Regulation (EU) 2023/1115](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2650&ref=sorena.io) - Supports using the amended EUDR timing and obligation structure rather than older unamended timing assumptions. - [Regulation (EU) 2023/1115 original legal text](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1115&ref=sorena.io) - Supports the original EUDR legal basis and the SME terminology used for micro, small, and medium-sized undertakings. ## FAQ Pagination - Canonical index (page 1): [/artifacts/eu/deforestation-regulation/faq/items](/artifacts/eu/deforestation-regulation/faq/items.md) - Page 1 rule: `/page/1` is intentionally not generated; use the canonical index markdown URL. - Current page: 2 of 3 Pages: [1](/artifacts/eu/deforestation-regulation/faq/items.md) | [2](/artifacts/eu/deforestation-regulation/faq/items/page/2.md) | [3](/artifacts/eu/deforestation-regulation/faq/items/page/3.md) [Previous page](/artifacts/eu/deforestation-regulation/faq/items.md) | [Next page](/artifacts/eu/deforestation-regulation/faq/items/page/3.md) *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. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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