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
Use the checklist to support a reasoned decision
An EUDR due diligence checklist should confirm that the operator has identified the relevant goods, collected and checked the required evidence, assessed and mitigated risks where necessary, and completed the applicable pre-placement or export process. A ticked form is useful only when its answers refer to records and explain the decision for the actual product.
Use this checklist within the complete due diligence framework. It addresses an ordinary operator's main workflow while flagging different regimes. The current legislation separates operators, downstream operators and traders, and provides a narrow Article 4a primary-operator regime. Select the correct process before assigning tasks; do not assume every business in the chain submits another ordinary statement.
As verified on 16 October 2026, the main general application date is 30 December 2026, with specified later dates and exceptions. Record the product and actor-specific date supporting your implementation plan. The checklist is a practical aid based on the current law, not evidence that future obligations already apply to every transaction on the verification date.
Confirm scope, role and origins
First, identify the relevant product, its classification and relevant commodities. Check Annex I using the actual goods and composition. Record any scope limitation or deferred application date with its basis. For an existing foundation product, do not assume that a nearby new product code has identical treatment merely because the commercial descriptions sound similar.
Second, identify the business entity and its role for the transaction. Record whether the goods are being placed, made available or exported and why the entity is an operator or another actor. Where Article 4a is considered, verify the precise eligibility conditions. Where Article 13 is considered, record the separate basis for qualifying low-risk production and the required complexity and mixing assessment.
Third, establish the production origin set. Identify the country and relevant parts, all applicable plots or cattle establishments, and production dates or ranges. Connect these sources through aggregation and processing to the actual product. Record any unknown contribution, substitution or unresolved link rather than allowing the checklist to proceed on the basis of a supplier's general farm register.
Check the information and substantive conditions
Confirm the product description, relevant commodities or products used, and wood species information where required. Reconcile quantity and applicable units with the actual goods. Identify the supplier and required business recipients by name, postal address and email. Check whether identifiers and dates match across purchasing, movement and production records.
Evaluate the deforestation-free evidence for the actual locations and periods, using the regulatory definitions. For relevant wood, include forest degradation where applicable. Confirm that evidence addresses the historical cut-off rather than only current tree cover. Record limitations in maps, imagery or location information and explain how they were resolved or why they affect the decision.
Evaluate lawful production separately. Identify the relevant legislation in the country of production and the evidence addressing the applicable rights and requirements. Do not equate a permit with complete legality, or legal clearance with deforestation-free status. Check that the documents concern the correct producer, location, activity and period. Flag contradictory or unverifiable records for investigation.
Assess risk and verify mitigation
For the ordinary assessment, verify how Article 10 criteria were considered, including information reliability, country and local circumstances, relevant indigenous peoples' claims, chain complexity, mixing and circumvention. Ask whether the explanation supports no or negligible risk for the actual product. A favourable numerical supplier score without source-specific reasoning is not enough.
Where risk is not no or negligible, identify the concern and the Article 11 measures used to address it. Record the evidence obtained, findings and remaining limitations. Check that an audit or survey covered the relevant issue and affected supply-chain stage. Do not approve the product merely because an investigation has been commissioned or the supplier has promised a later correction.
For Article 13 simplified due diligence, confirm that its qualifying conditions remain true and that no relevant information requires full assessment and mitigation. Document the basis for negligible circumvention or mixing risk. Low-risk status should not bypass Article 9 collection or lead staff to disregard a substantiated concern about the actual goods.
Control release and ongoing responsibilities
For an ordinary operator, record the supported compliance conclusion and prior statement submission before placement or export. Link the statement to the goods and communicate the required references under the applicable rules. Remember that a reference number is not authority approval. If the product is non-compliant, presents non-negligible risk, or the ordinary process cannot be fulfilled, stop the release.
Confirm retention and retrieval arrangements. Article 9 evidence runs for five years from placement or export; ordinary statement retention runs for five years from submission. Keep due diligence documentation and system updates under Article 12. Identify the people responsible for new information, immediate notifications where required, annual reviews and applicable public reporting.
Finally, record who made the decision, when and on what evidence. The internal controls process should ensure the warehouse follows that decision and that changes reopen it. Verify the checklist against the current Regulation when law, guidance, country classifications or supply arrangements change. Preserve unresolved issues explicitly so a completed form never conceals an incomplete compliance assessment.
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.