EU Deforestation Regulation Supplier evidence FAQ

Build the supplier evidence file around the product movement that will be placed on the EU market, made available, or exported. The record should identify who supplied the relevant product or commodity, what product or quantity the evidence supports, where the commodity was produced, and which due diligence statement reference number or simplified declaration identifier applies when one has been provided.

A supplier declaration is useful only if it can be reconciled with the commercial record and the origin evidence. Treat missing supplier identity, missing production origin, unsupported geolocation, unexplained mixing, or a reference number that cannot be tied to the product as unresolved EUDR risk rather than as a completed evidence file.

The supplier can provide records, but the operator owns the Article 9 verification, Article 10 conclusion, mitigation decision, and due diligence statement. An authorised representative can submit a statement; neither the supplier nor representative takes over Article 3 responsibility.

Article 9 information collection should let the operator demonstrate that the relevant product complies with the EUDR market-access conditions: deforestation-free, produced in accordance with relevant legislation in the country of production, and covered by the required statement or declaration. The supplier file has to connect commercial product data to origin data and supporting documents.

For each relevant product, collect the description and relevant commodity inputs, quantity, country and where relevant part of production, production date or time range, geolocation of every plot or cattle establishment, supplier and business-recipient identities, and adequately conclusive and verifiable information for deforestation-free and legal production.

Legal-production evidence depends on the laws applicable in the country of production. The EUDR categories include land-use rights, environmental protection, forest rules tied to wood harvesting, third-party rights, labour rights, protected human rights, free prior and informed consent, and tax, anti-corruption, trade, and customs rules. Identify the applicable rule and document rather than collecting a generic legality certificate.

Where Article 10 applies, supplier evidence feeds the risk assessment; it does not replace it. For Article 13 simplified due diligence, retain the Article 9 information and the separate complexity, circumvention, and mixing assessment. Test the evidence's source, reliability, validity, and links to other documents. Also assess country risk, forest and deforestation context, indigenous peoples' rights and reasoned land claims, supply-chain complexity, processing stage, plot traceability, mixing, circumvention, substantiated concerns, and compliance history where relevant.

Certification and third-party verification may provide complementary Article 10 information, but only when the information meets Article 9 requirements. The Commission's July 2026 guidance is non-binding and explains that schemes do not remove the operator's duty to exercise due diligence or responsibility for compliance.

If the evidence is incomplete or inconsistent, record the gap and mitigate before the product is placed on the market or exported. Article 11 examples include requesting additional documents and carrying out independent surveys or audits. Depending on the facts, the operator may also segregate mixed lots, reject unsupported inputs, or hold the shipment until the evidence supports the risk conclusion.

Operators use supplier and origin evidence before submitting or making available the due diligence statement through the Article 33 information system. The statement should not be assembled from a disconnected certificate archive; it should point back to the product, supplier, geolocation or establishment, legal-production, risk assessment, and mitigation records that support the conclusion.

Downstream operators and traders must keep the Article 5 supplier and business-recipient details. They must collect statement reference numbers or declaration identifiers when their direct supplier is an operator. Article 4(7) requires operators to communicate associated references or identifiers further down the supply chain; Article 5 does not impose a general reference-forwarding duty on every later trader.

Keep records so a reviewer can reconstruct the supplier chain. Operators retain due diligence documentation for at least five years and statement records for five years from submission. Downstream operators and traders retain Article 5 information for at least five years from their own placing, making available, or export and provide it to competent authorities on request.

A useful retention file contains both the upstream evidence and the downstream handoff: supplier details, product and quantity linkage, origin and geolocation evidence, legal-production documents, risk assessment result, mitigation record if used, due diligence statement reference number or declaration identifier, and downstream recipient information.

Avoid treating a supplier attestation, certificate, or reference number as complete EUDR evidence by itself. The supplier file has to remain connected to the actual product movement and to the Article 9, risk assessment, statement, and retention records behind the release decision.

Article 4a contains one specific geolocation adjustment: a micro or small primary operator may replace Article 9(1)(d) geolocation with the postal address of all plots or the cattle establishment. Do not turn that into a general shortcut for other suppliers. The ordinary Article 2 rule requires six-decimal coordinates and a polygon for each non-cattle plot larger than four hectares.