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 4 and 8 to 12
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
Treat a supplier change as a defined review trigger
A change of supplier can alter the product's production origins, evidence reliability, supply-chain complexity and compliance risk. An EUDR operator should therefore assess what changed before relying on an earlier due diligence conclusion. The required response depends on the facts: replacing a sales contact is different from buying commodities produced on previously unidentified plots.
A change can occur without a new invoice issuer. An existing exporter may start buying from another cooperative, a mill may add a spot-market source, or a processor may subcontract production. The due diligence system should look through the commercial supplier name to the sources and chain relevant to the actual product.
Articles 8 to 11 require information, assessment and, where necessary, mitigation before ordinary operator placement or export. Article 12 requires the system to stay up to date. Do not make supplier-change review an after-the-event onboarding task if the goods can be released in the meantime. Hold the affected product until the applicable evidence and decision requirements are satisfied.
Identify the type of change
A legal-entity change may require revised identity details, contracts and assessment of whether existing permissions and records remain valid. A new producer or production country affects origins and the relevant legislation. A new plot affects geolocation and land history. A new processor or store can change the traceability path and the risk of mixing. Record which category applies rather than using a single undifferentiated change flag.
Changes in ownership or management can also affect the reliability of assurances and controls. They do not automatically make a product non-compliant, but the operator should assess whether the earlier verification remains meaningful. If records previously obtained through a cooperative are no longer accessible, the business needs an alternative evidence route before treating later goods as covered.
Some changes are corrections rather than new sources. A supplier might correct an incorrectly typed address or replace an imprecise plot name with a stable identifier. Preserve the old value, corrected value and verification of the explanation. This prevents an apparent clerical correction from silently concealing substitution of the production origin.
Collect and compare the new evidence
Build a comparison between the approved flow and the proposed flow. Check product composition, quantities, commodity and species information where relevant, country, locations, production periods, supplier identities, processing stages and storage arrangements. Identify which old records still apply and which cannot support the changed goods. This is more efficient than requesting an entirely new file without understanding the difference.
For a new production country, reassess the relevant production laws and current country classification. A permit format used in the previous country may have no significance in the new one. For a new plot in the same country, examine the actual plot's deforestation history and applicable rights rather than assuming nearby approved production covers it.
If a new intermediary is introduced, require enough records to connect purchases to the final goods. The fact that the final exporter remains certified does not prove the added intermediary keeps production sources identifiable. Check whether physical movements, processing records and quantities support the proposed chain, especially where multiple sources are aggregated.
A timber substitution example
A furniture factory normally uses timber from a reviewed sawmill but proposes a replacement because of a production delay. The replacement timber has the same commercial grade and appears identical in the finished item. That product similarity does not establish the same species, forest origin or relevant legal-production evidence. The operator needs to understand what material was actually used.
The assessment should identify the replacement species, required scientific name, production locations, harvesting period and chain through the new sawmill. It should address the deforestation-free definition, including forest degradation where relevant, and the applicable production law. Existing evidence for the original sawmill may still explain factory processes, but cannot prove the new forest source complies.
If the replacement stock was already mixed into production and the factory cannot identify the affected orders, the operator must investigate the scope of the uncertainty. It should not simply approve future deliveries from the new sawmill and assume the earlier mixture is retrospectively covered. Record the affected product pool and the evidence needed to resolve it.
Control approval, communication and later consequences
Set clear authority for accepting a changed flow. Procurement can request the change, but the compliance decision needs the relevant evidence and a documented risk conclusion. Where mitigation is required, define its purpose and assess its effectiveness. A commercial promise that the new source will become documented soon does not establish no or negligible risk now.
Communicate approved changes to warehouses, logistics and statement-submission teams. Update the goods-to-evidence connection and any required submission information under the applicable official rules. If the change affects quantities or sources already allocated to an existing statement, check that statement's actual coverage and the permitted amendment or replacement process. A reference number should never be treated as flexible coverage for any substitute goods.
The supplier information process should require notice of relevant changes and preserve evidence versions. If the discovery concerns goods already placed, assess the immediate Article 4(5) notification duty as well as pending releases. Review decisions against the current Regulation. A documented change assessment protects continuity by showing exactly why the revised supply remains acceptable or why it must be stopped.
Primary sources on the record
Articles 4 and 8 to 12. 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.