Deforestation-Free Evidence Checklist

Organise evidence around the legal questions

A deforestation-free evidence file should establish the actual production locations, relevant historical land condition, any post-cut-off conversion and, for wood, the separate harvesting-induced degradation condition. It should connect those findings to the goods being assessed, not merely describe a supplier's general sustainability policy.

This checklist supports evidence organisation; it does not create a universal list of mandatory certificates. The suitable documents and observations depend on source land, commodity, supply chain and identified risks. The ordinary operator remains responsible for the due diligence conclusion required by the Regulation.

Use the deforestation-free requirement alongside the current Articles 2, 9 and 10. The July 2026 guidance explains important land-use and evidence distinctions.

Identify goods and validate source locations

Record the relevant product, commodity relationship, supplier, quantity and lot or shipment identifiers. Confirm scope separately, including Annex I descriptions and any exclusions or deferred product application. A well-evidenced forest assessment does not itself establish that every finished product is covered.

List the actual production plots or relevant cattle establishments and retain the source information linking them to the goods. Check coordinates, boundaries, dates and whether a polygon describes a property or production subarea. Resolve obvious offsets or missing areas before running map-based checks.

For multiple origins, preserve all relevant source links. A clean result for one plot or a representative farm does not automatically support goods from other areas. Purchasing and production records should explain the source coverage of the evidence file and identify additions or substitutions.

Establish the baseline and post-cut-off history

Use suitable dated evidence to assess whether the land met the forest definition around the relevant historical baseline. Apply the area, tree height, canopy or growth-capacity conditions together with predominant land use. Do not treat every tree-covered agricultural system as forest or every temporary forest opening as non-forest.

Then identify any changes after 31 December 2020 and the subsequent land use. Agricultural conversion requires the relevant forest-to-agriculture change. Record evidence dates and gaps, especially where observations bracket a possible conversion across the cut-off.

Possible sources include image sequences, land-use records, production history and management information. Assess what each source establishes and compare inconsistencies. Administrative labels can complement the file, but the guidance says actual forest properties prevail over inconsistent land-register designations.

Add the wood degradation assessment where relevant

For wood-containing relevant products, identify the source forest category, harvesting event and resulting transition. Article 2(7) defines specific changes involving primary, naturally regenerating, plantation and planted forests and other wooded land. A generic tree-loss score does not establish every element.

Forest inventories, management and regeneration information may complement imagery. Record the spatial and temporal coverage and how the evidence relates to the actual harvested wood. A permit or certificate should be assessed for its scope rather than accepted as proof of all forest conditions.

Keep this finding distinct from agricultural conversion. The absence of crops or pasture after harvest does not alone resolve the degradation question. Conversely, avoid describing every harvest opening as degradation without establishing the listed structural transition and harvesting connection.

Review reliability, conflicts and remaining risk

For each important source, record provenance, date, version, coverage and limitations. A screenshot without coordinates or observation date can be difficult to review later. An automated map score should retain enough underlying information to explain why it supports the conclusion.

Investigate alerts and conflicting evidence. A satellite signal is not conclusive proof of legal conversion, but should not be dismissed without reasoning. A clean layer is likewise not a guarantee, especially where boundaries, resolution or the land-use classification are unsuitable.

The satellite-evidence review gives a practical interpretation sequence. State unresolved uncertainty and further information or mitigation needed before reaching no or negligible risk. Do not substitute a supplier warranty for a material gap in the source-land assessment.

A useful completeness check asks another reviewer to trace one actual shipment back through the evidence file. They should be able to identify the source list, open the relevant historical records, understand any alerts and find the reason for the conclusion without asking the original analyst to reconstruct it. If they find only a supplier certificate and an undated green map, identify which legal questions remain unsupported. Improve the missing links or evidence rather than adding unrelated documents merely to make the folder look substantial.

Approve, retain and update the conclusion

The final record should identify the reviewer, approval date, goods, production sources, evidence, legal classification and risk conclusion. Keep the lawful-production condition and required statement or declaration coverage separately assessed, since absence of deforestation alone does not establish full Article 3 compliance.

Retain the records under the applicable EUDR obligations and make them accessible for authority checks. Connect new supplier information to affected lots and customers so the business can apply the correct notification and cooperation duties if a problem emerges after supply.

Review when production boundaries, origins, management, imagery or credible new information changes. A useful checklist records why the evidence was adequate for the actual products and when that conclusion must be reopened, rather than producing a permanent green badge for a supplier regardless of later events.