---
title: "Requirements"
canonical_url: "https://www.sorena.io/artifacts/eu/deforestation-regulation/requirements"
source_url: "https://www.sorena.io/artifacts/eu/deforestation-regulation/requirements"
author: "Sorena AI"
description: "A structured EUDR requirements map: Article 3 core conditions, operator obligations in Article 4, simplified declaration rules in Article 4a."
published_at: "2026-02-22"
updated_at: "2026-02-23"
keywords:
  - "EUDR requirements"
  - "EU Deforestation Regulation obligations"
  - "Article 3 deforestation free legality due diligence statement"
  - "operator obligations Article 4 EUDR"
  - "downstream operator trader obligations Article 5 EUDR"
  - "due diligence system Article 8 9 10 11"
  - "geolocation requirements EUDR"
  - "EUDR information system Article 33"
  - "EU compliance"
  - "EUDR compliance"
  - "requirements"
  - "due diligence"
  - "geolocation"
---
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# Requirements

A structured EUDR requirements map: Article 3 core conditions, operator obligations in Article 4, simplified declaration rules in Article 4a.

*Artifact Guide* *EU*

## EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence Requirements

A structured obligations map plus an evidence checklist you can execute.

Use this as the backbone for your requirements doc, supplier onboarding pack, and due diligence statement workflows.

EUDR compliance becomes manageable when you map obligations to roles and artifacts. The Regulation distinguishes operators, downstream operators and traders, and it organizes compliance around a due diligence system (information collection, risk assessment, risk mitigation) and a due diligence statement workflow. This page turns that into a practical requirements map and an evidence checklist.

## 1) The core gate (Article 3): no market placement/export unless three conditions are met

EUDR's operational trigger is straightforward: you must not place, make available, or export relevant products unless they meet the core conditions and are covered by a due diligence statement (or simplified declaration where applicable).

Treat this as a hard shipping/release control.

- Deforestation-free condition: define your evidence approach and data sources
- Legality condition: define what 'relevant legislation' evidence looks like for each country of production
- DDS/simplified declaration condition: implement reference number controls and retention

## 2) Operator obligations (Article 4) - where the heavy lifting sits

Operators must exercise due diligence before placing on the market or exporting to demonstrate compliance with Article 3, and they must not do so without prior submission of a due diligence statement unless Article 4a gives them access to the simplified declaration route.

By making the due diligence statement available, or using a simplified declaration where the Regulation permits it, the operator assumes responsibility for Article 3 compliance.

- Perform due diligence before placement/export (due diligence system in Articles 8-11)
- Submit due diligence statement via the information system before placement/export
- Retain due diligence statements and references for five years
- Communicate due diligence statement reference numbers/identifiers downstream

## 3) Simplified declaration path for micro or small primary operators (Article 4a)

Micro or small primary operators have a specific simplified declaration route. It is not a general shortcut for all small companies, so teams should document eligibility before using it.

Where Article 4a applies, the operator receives a declaration identifier and may use the postal address simplification for Article 9(1)(d) geolocation.

- Confirm the operator is established in a low risk country and fits the micro or small primary operator definition
- Submit the one time simplified declaration before placing on the market or exporting
- Store the declaration identifier and communicate it downstream just as carefully as a DDS reference number

## 4) Downstream operators and traders (Article 5) - traceability and information retention

Downstream operators and traders must ensure they possess required information before placing/making available/exporting and must keep information for years and provide it to competent authorities on request.

Non-SME downstream operators and non-SME traders have additional system registration requirements.

- Collect and retain supply chain information, including supplier details and DDS reference numbers/identifiers where applicable
- Retain Article 5 information for at least five years and provide it upon request
- If new information indicates risk/non-compliance: inform competent authorities and downstream recipients
- Non-SME downstream operators/traders: register in the information system before placing/making available/exporting

## 5) The due diligence system (Articles 8-11): information, risk assessment, mitigation

EUDR due diligence has three operational steps: collect information and evidence, assess risk, and mitigate risk when it is not negligible.

Design your workflow so that risk decisions are auditable and tied to evidence.

- Information collection (Article 9): include evidence demonstrating deforestation-free and legal production and geolocation of plots/establishments (as applicable)
- Risk assessment (Article 10): decide whether risk is no/only negligible before placing/exporting
- Risk mitigation (Article 11): if risk is not negligible, implement mitigation before placing/exporting
- Evidence: risk model inputs, decisions, mitigation actions, and post-mitigation reassessment

## 6) Simplified due diligence for low risk production

EUDR includes simplified due diligence in low risk contexts under the benchmarking system, but teams must still control circumvention and mixing risks.

This is different from the Article 4a simplified declaration route for micro or small primary operators.

- Low-risk production: document why risk of circumvention/mixing remains negligible and keep evidence
- Keep evidence showing why the supply chain complexity does not create circumvention or mixing risk
- Even with simplified due diligence, keep your evidence pack audit ready

## 7) Evidence mapping - requirement -> artifact

Most EUDR disputes are evidence disputes. Build an evidence pack that is produced by the workflow, not retrofitted later.

Use this as a minimal mapping; expand per commodity and supplier risk profile.

- Scope mapping -> SKU -> Annex I table + owner + change log
- Operator gate -> DDS submission proof or simplified declaration record + identifier storage + retention
- Geolocation -> validated plot data + provenance + batch/lot linkage
- Risk assessment -> risk model inputs + decisions + approvals
- Risk mitigation -> mitigation actions + supplier corrective actions + reassessment results
- Downstream obligations -> reference number handoff + Article 5 information retention pack

*Recommended next step*

*Placement: after the requirement breakdown*

## Operationalize EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence Requirements across ESG workflows

ESG Compliance can take EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence Requirements from turning the requirements into assigned actions to a reusable workflow inside Sorena. Teams working on EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

- [Open ESG Compliance for EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence Requirements](/solutions/esg-compliance.md): Start from EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence Requirements and manage cross team sustainability work, reporting, and evidence from one workflow.
- [Talk through EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence](/contact.md): Review your current process, evidence gaps, and next steps for EU Deforestation Regulation (EUDR): Deforestation-Free Products and Due Diligence Requirements.

## Primary sources

- [EUDR key definitions and obligations (extracts) - Eur-Lex (ELI)](https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng?ref=sorena.io) - Definitions for operator, downstream operator, trader, and micro or small primary operator, plus Article 3 scope trigger, Article 4 and 4a submission duties, Article 5 downstream duties, and the due diligence structure in Articles 8 to 11.
- [European Commission - EUDR overview page](https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en?ref=sorena.io) - High-level overview and implementation context for EUDR obligations.

## Related Topic Guides

- [Applicability Test | EU Deforestation Regulation (EUDR): In-Scope Products, Roles, Dates](/artifacts/eu/deforestation-regulation/applicability-test.md): A 15-minute EUDR applicability test: confirm whether your commodities or products are in Annex I, determine if you are an operator, downstream operator.
- [Compliance Program | EUDR Implementation Playbook: Governance, Controls, Supplier Onboarding, Evidence](/artifacts/eu/deforestation-regulation/compliance.md): Turn EUDR into an execution program: governance and ownership, SKU -> Annex I scope mapping, supplier onboarding data contracts, geolocation pipeline.
- [Deadlines and Compliance Calendar | EUDR Key Dates 2024 to 2029](/artifacts/eu/deforestation-regulation/deadlines-and-compliance-calendar.md): EUDR deadline tracker with actionable milestones: information system readiness under Article 33, Commission benchmarking timing.
- [Deadlines, Phasing, and What to Do First | EUDR Implementation Plan (90 Days -> Go-Live)](/artifacts/eu/deforestation-regulation/deadlines-phasing-and-what-to-do-first.md): A practical EUDR phasing guide: what to do first, what to build next, and how to sequence scope mapping, geolocation data collection, supplier evidence.
- [Due Diligence Statement (DDS) and Evidence Pack | EUDR: What to Collect, Store, and Prove](/artifacts/eu/deforestation-regulation/due-diligence-statement-and-evidence.md): EUDR due diligence statements made practical: what a DDS is, when a simplified declaration applies, who submits it, how reference numbers flow downstream.
- [EUDR Checklist | EU Deforestation Regulation Compliance Checklist (Scope -> DDS -> Evidence)](/artifacts/eu/deforestation-regulation/checklist.md): A practical EUDR checklist organized by workstream: scope mapping (Annex I), role mapping (operator/downstream operator/trader), geolocation pipeline.
- [EUDR Due Diligence Statement Template | Copy/Paste DDS Structure and Evidence Checklist](/artifacts/eu/deforestation-regulation/eudr-due-diligence-statement-template.md): A practical EUDR due diligence statement (DDS) template outline: the fields and annexes you should prepare (product identification, supplier and origin data.
- [EUDR vs CSDDD | What's Different, What Overlaps, and How to Build One Evidence Program](/artifacts/eu/deforestation-regulation/eudr-vs-csddd.md): EUDR vs CSDDD made practical: EUDR is product-and-lot specific with DDS reference numbers, geolocation, and deforestation-free/legality conditions.
- [FAQ | EUDR Explained: Scope, Roles, DDS Reference Numbers, Geolocation, Risk Mitigation, Penalties](/artifacts/eu/deforestation-regulation/faq.md): EUDR FAQ with practical answers: what is in scope (Annex I), operator vs downstream operator vs trader, what a due diligence statement (DDS) is.
- [Geolocation Data Requirements | EUDR: Plots of Land, Establishments, Validation, Exceptions](/artifacts/eu/deforestation-regulation/eudr-geolocation-data-requirements.md): EUDR geolocation requirements made practical: what geolocation data to collect (plots/establishments).
- [Geolocation, Traceability, and Systems | EUDR Technical Architecture and Data Model](/artifacts/eu/deforestation-regulation/geolocation-traceability-and-systems.md): Build EUDR ready systems: geolocation pipeline, batch and lot traceability, evidence storage, and risk control workflows.
- [In-Scope Commodities and Products (Annex I) | EUDR Scope Mapping Guide](/artifacts/eu/deforestation-regulation/in-scope-commodities-and-products.md): EUDR scope mapping guide for Annex I commodities and derived products: how to map SKUs to relevant commodities/products, handle composite goods and blends.
- [Penalties and Enforcement | EUDR Enforcement Actions, Corrective Measures, Interim Measures, Reporting](/artifacts/eu/deforestation-regulation/penalties-and-enforcement.md): How EUDR enforcement works in practice: competent authority checks, interim measures (including seizure/suspension).
- [Penalties and Fines | EUDR Penalty Framework (Article 25): Turnover-Based Fines and Other Measures](/artifacts/eu/deforestation-regulation/penalties-and-fines.md): EUDR penalties explained (Article 25): Member State penalty rules.
- [Risk Assessment and Mitigation | EUDR Due Diligence (Articles 10-11) Playbook](/artifacts/eu/deforestation-regulation/risk-assessment-and-mitigation.md): EUDR due diligence risk assessment and mitigation made practical: how to structure Articles 10-11 decisions, what inputs to use (origin, supplier.


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