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, 4a, 5 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
Start with decisions the system must control
An EUDR due diligence system is the framework of procedures and measures an operator establishes and maintains under Article 12 to ensure its relevant products comply with Article 3. It should connect evidence collection, risk decisions, mitigation, statement submission and release. Buying a platform or writing a policy is only useful if those parts work for the goods the business actually handles.
Begin with a map of products, transactions and actors. Identify relevant product scope, the relevant commodities, production structures and whether each business entity acts as an operator, downstream operator or trader. A corporate group may have different roles across legal entities and product flows. Avoid imposing the same statement workflow on every subsidiary merely because they share an enterprise resource planning system.
The due diligence requirements then become business decisions: which evidence is necessary, what risks must be assessed, what prevents release, and who handles new information. The current general application date is 30 December 2026, with specified later dates and exceptions. Establish the actual application rule for each flow before setting implementation priorities.
Design the evidence model
Create connected records for the relevant product, lot, quantity, production country, production location, production period, supplier and recipient. Keep commodity and species information where required. Use stable identifiers so records from procurement, warehouses and evidence reviews can be reconciled. An electronic folder named after a supplier may store documents but usually cannot explain which shipment used which production origins.
For each Article 9 field, specify the source, owner and verification method. Supplier identity may be checked through business records; production plots require suitable location evidence; lawful production requires analysis of applicable country law. Record limitations and unresolved discrepancies rather than allowing blank values to inherit an approved supplier status automatically.
Retain original evidence and version history. A later corrected plot boundary should not overwrite the geometry used in an earlier decision without explanation. Separate master data from transaction data: a farm's identity may remain stable, while harvest periods, supplied quantities and the farms contributing to an aggregated lot can change. This distinction supports reuse without obscuring changes.
Build a documented assessment method
Translate Article 10 criteria into a review appropriate to the supply chain. Cover information reliability, country and local context, forest and deforestation factors, indigenous peoples' rights, chain complexity, mixing and circumvention, and other relevant information. A structured form can ensure coverage, but reviewers need room to explain why particular evidence supports or undermines the conclusion.
Define how Article 13 simplified due diligence is authorised. The decision needs to establish qualifying low-risk production and assess complexity and circumvention or mixing. It should also specify what adverse information triggers full Article 10 and 11 work and immediate communication to the authority. Do not let low-risk country selection bypass the information stage.
Set an escalation path for unresolved concerns. Procurement staff should know when to involve legal, technical land-cover or traceability expertise. If mitigation is needed, identify the problem, chosen measure, owner, deadline and test of effectiveness. A task marked audit completed should not clear a hold unless the findings actually resolve the relevant risk.
Make release an explicit controlled event
For ordinary operators, require a supported no or negligible risk decision and prior statement submission before placement or export. Connect the statement to the goods. Logistics should receive an unambiguous release status, not a long evidence discussion from which it must infer permission. A reference number alone should not automatically release a lot if the underlying review is incomplete.
Design holds to follow the stock through movements, processing and order changes. If the original shipment is split, the release record should explain which quantities and sources remain covered. If approved and unresolved material are mixed, the process must reassess the relevant pool rather than preserving the approved label on the original quantity by accounting convention.
Create separate workflows for the narrow Article 4a primary-operator regime and Article 5 downstream and trader duties. Eligibility must be documented. An employee should not select simplified because the ordinary statement form is inconvenient. Use clear labels distinguishing a simplified declaration from simplified due diligence for qualifying low-risk production.
Maintain, test and report
Article 12 requires system review at least once a year and updates when new developments could influence it. Risk assessments and mitigation decisions also have annual review requirements. Add event-based triggers for changed suppliers, plots, laws, concerns and chain arrangements. Assign responsibility for monitoring those triggers so the system is maintained between scheduled reviews.
Non-SME operators must address the management-level compliance officer and independent audit function requirements in Article 11. Article 12 annual public reporting applies outside its specified SME and natural-person exclusions. Define these responsibilities separately from routine shipment review. A public report cannot replace the underlying decision records or an independent examination of whether controls work.
Test a real transaction from purchase order to retained evidence and statement reference, then test an exception involving an unknown source. The internal controls guidance explains how to make those checks meaningful. Retention schedules must recognise the different clocks in Articles 4, 9 and 12. Use the current Regulation as the controlling reference and keep a dated record of system changes.
Primary sources on the record
Articles 4, 4a, 5 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.