Filed under EUDR Due Diligence Explained: Information, Risk and Compliance
Plot record: legal status and review details
- Jurisdiction
- European Union
- Status
- Current consolidated Regulation (EU) 2023/1115, including the 2025 amendment and September 2026 consolidation. Main obligations are not yet generally applicable on the verification date.
- Application
- Generally 30 December 2026; 30 June 2027 for eligible micro and small operators, subject to the timber exception; some newly added products apply from 30 December 2027. Check the product and actor-specific rules.
- Relevant provisions
- Articles 3, 4 and 8 to 13
Review this page when:
- Amendments to Articles 3 to 13
- New Commission due diligence guidance or FAQs
- Changes to country benchmarking
- Application dates and product-scope changes
Assess every relevant origin in the product
Products with several production origins require due diligence that accounts for all relevant commodity sources, rather than selecting one representative farm or the final processing country. Article 9 requires the production country and the geolocation of all applicable plots where the relevant commodities were produced, together with production dates or time ranges. For cattle-related products, the specific establishment rule applies.
The challenge is both completeness and connection. An operator needs to know that the listed origins cover the actual goods, and that every relevant source meets the applicable conditions. A long origin list is not enough if it excludes spot purchases or cannot be linked to the shipment. Conversely, unrelated farms added for convenience do not explain the actual product's source.
The due diligence framework should treat aggregation as a traceability question before reaching a risk conclusion. Identify where materials are combined, what records explain the contributions, and whether any unknown or unresolved source can enter the same pool. The final country of dispatch does not replace the countries where the relevant commodities were produced.
Map origins through processing
Start with a product and material map. Identify the relevant commodities and products used, the production sources and the processing steps that connect them to the finished goods. For a blended coffee shipment, this can involve farms, cooperatives, stores and the final blending facility. For furniture, it can involve several timber components, species and sawmill chains.
The map should explain quantities using appropriate units and realistic processing relationships. Raw material input and finished output need not be identical, but the difference should be intelligible. An operator should investigate an apparent output that cannot be explained by the recorded sources. Such a discrepancy may indicate missing origins, inaccurate units or an incorrect allocation of stock.
Preserve production dates or time ranges for the actual source material. A multi-origin lot may include different harvest periods or production events. Avoid replacing them with the container loading date. The loading date describes logistics, while the Article 9 production information helps establish what commodity was produced at the identified locations and which evidence applies.
Evaluate source-specific and combined risks
Each origin can present different deforestation, legality and information-reliability issues. Evidence sufficient for one country or parcel may not establish compliance at another. Identify applicable laws for the actual sources and assess relevant rights and concerns. A global supplier declaration should not erase differences between the legal and production circumstances of contributing farms.
The combined chain can create additional risks beyond the individual farm files. Aggregation may allow unknown material to enter a store, or processing may obscure which inputs reached the EU product. Article 10 expressly addresses complexity, difficulties connecting goods to production plots, mixing and circumvention. Review those relationships rather than averaging individual farm ratings into one apparently favourable number.
Article 13 simplified due diligence requires all relevant production to qualify under low-risk classifications, alongside its complexity and mixing assessment. A single source from a standard-risk or high-risk country affects eligibility for that route for the relevant mixed product. Processing all the material in a low-risk country does not change the original production origin.
A mixed cocoa lot example
An exporter combines cocoa from two cooperatives in one warehouse lot. Both cooperatives provide producer lists, but one also buys from independent village agents. The operator must establish whether the agents' beans entered the intended lot and, if so, obtain the relevant production origins and evidence. The completeness of the other cooperative's files cannot compensate for this missing contribution.
If records show that the agent-sourced beans remained in a separate identified store and did not contribute to the lot, the operator can evaluate that segregation evidence. If the material was physically mixed and no reliable source connection remains, an accounting allocation assigning approved beans to the EU customer does not necessarily resolve the uncertainty about the goods actually supplied.
The response may involve obtaining missing records, verifying the chain independently or isolating an unaffected product pool where evidence supports that distinction. The operator must assess the results before release. It cannot knowingly include a non-compliant origin on the basis that its proportion in the mixture is small; the substantive product conditions remain applicable.
Keep the origin set maintainable
Use stable origin identifiers and retain the evidence version reviewed for each source. Link the final product lot to its contributing origins and to the assessment and required statement. Where an aggregation pool changes over time, record when the source set changed and which lots were affected. A current master list should not overwrite the list used for an earlier decision.
Have a process for corrections and later concerns. If a source is discovered to be misidentified or associated with a relevant rights claim, determine which products contain material from it. This supports both pending release decisions and applicable post-market notification duties. Without a source-to-product connection, the business may be unable to define the affected scope reliably.
Coordinate this work with supplier-change due diligence, because new origins often arrive through an unchanged supplier. Check the current Articles 9, 10 and 13 when designing origin controls. The objective is not a decorative map of many farms, but a complete, testable explanation of the sources behind the actual relevant product.
Primary sources on the record
Articles 3, 4 and 8 to 13. This entry was checked against the consolidated text dated 18 September 2026. Consolidated texts are documentation tools; the authentic acts are those published in the Official Journal.
Check the current sources and the guidance of the relevant competent authority for your situation. This page is not legal advice or a compliance determination.