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 file 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.

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. In practice, that means the supplier file has to connect commercial product data to origin data and supporting documents.

The grounding reviewed for this FAQ supports collecting and keeping information and evidence, including geolocation of plots of land or establishments and documentation demonstrating deforestation-free and legal production. Teams should therefore make geolocation and legal-production evidence mandatory fields in the supplier pack, not optional sustainability attachments.

Supplier evidence feeds the Article 10 risk assessment; it does not supersede it. The practical test is whether the evidence shows enough about the supplier, product, production origin, geolocation or establishment, legal-production documents, supply-chain complexity, and possible mixing or circumvention to support no or only negligible risk.

If the evidence is incomplete or inconsistent, record the gap and mitigate before the product is placed on the market or exported. Mitigation may include supplier clarification, additional origin documents, segregation of mixed lots, rejection of unsupported inputs, or holding 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 need supply-chain information too. Where the supplier is an operator, keep the supplier details and the due diligence statement reference number or simplified declaration identifier, then pass required references further down the supply chain.

Keep records in a way that a reviewer can reconstruct the supplier chain without relying on inbox searches. Operators keep due diligence statement records for five years, and downstream operators and traders keep Article 5 supply-chain information for at least five years 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.

The grounding reviewed for this FAQ supports one specific geolocation adjustment: for micro or small primary operators, Article 9(1)(d) geolocation may be replaced by the postal address of plots of land or the establishment. Do not turn that into a general shortcut for other suppliers, and do not publish unsupported coordinate-format, polygon-threshold, penalty, or deadline claims in the supplier evidence FAQ.