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(5), 10(4), 11(3), 12 and 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
Annual review is the minimum, with event-based updates
Article 12 requires operators to review their EUDR due diligence system at least once a year. It also requires updates when new developments could influence the system, with records of those updates retained for five years. A scheduled annual meeting therefore does not justify waiting to address a new source, material legal change or credible non-compliance concern.
The system review is distinct from the at-least-annual reviews of risk assessments under Article 10 and mitigation decisions under Article 11. These exercises can be coordinated, but each must address its own subject. Reviewing the policy document does not establish that a particular product assessment remains reliable or that mitigation measures achieved their intended result.
Start with the due diligence system's actual operating scope. Confirm the products, legal entities, roles and supply flows it covers. The revised operator, downstream-operator and trader model must be reflected in procedures. If the business has added an import flow or started processing previously covered products, last year's role map may no longer support the current workflow.
Review legal and supply-chain changes
Check amendments, current Commission guidance and relevant official system documentation. Identify changes that affect scope, actor duties, information fields, submission procedures, country classifications or application dates. Keep a short impact record explaining which product flows and procedures are affected. Merely saving the new document in a legal folder does not update the system.
Review supplier, producer, country, plot, processing and storage changes. Determine whether new intermediaries or aggregation practices increase the difficulty of connecting goods to origins. Check whether an apparently stable supplier has changed its underlying purchases. Sample actual transactions against the approved source set, rather than relying only on a supplier's general assurance that nothing important has changed.
For Article 13 simplified due diligence, reassess the conditions supporting its use. Confirm current classifications and the evidence concerning complexity, mixing and circumvention. Relevant information indicating non-compliance or circumvention requires the full Article 10 and 11 process and immediate communication to the authority under Article 13. The review should test whether staff recognise and act on those triggers.
Test the quality of evidence and decisions
Choose a sample that includes different commodities, origin structures and risk situations. Check whether Article 9 information is complete, verifiable and connected to the actual goods. Look for inconsistent coordinates, missing production periods, quantities without correct units, unsupported species names and gaps between farm records and processed products. An assessment can appear complete while drawing on unrelated evidence.
Read the risk reasoning. Does it explain how relevant Article 10 criteria were considered, or merely reproduce a low supplier score? Where a concern was identified, examine the chosen mitigation and its outcome. An independent audit may have been completed without covering the problematic intermediary. The review should identify that limitation rather than accepting the existence of an audit report as closure.
Reconstruct a decision as another reviewer would. Identify what the operator knew, what it checked, why it accepted the goods and how the statement or applicable identifier links to them. If the reasoning exists only in the memory of one buyer, strengthen the record before staff changes or authority requests expose the gap.
Review controls, reporting and retention
Test whether release gates prevent unsupported placement or export. Include held stock, split lots, substitutions and manual overrides. Check whether warehouse and customs teams receive accurate status information. A review that verifies the policy says do not release but never tests dispatch records cannot establish that the control operates.
For non-SME operators, examine the management-level compliance officer and independent audit arrangements required by Article 11. Review findings, corrective action and overdue issues. Also check Article 12 annual public reporting where applicable, including the required product and origin summary, risk and mitigation conclusions, evidence description and relevant consultation processes. The public report is distinct from confidential evidence retention.
Review the different retention clocks under Articles 4, 9 and 12. Test access to older files and supplier-platform exports. Verify that shared evidence remains available for later placements relying on it. The record retention guidance explains why one deletion date based on supplier onboarding can leave later transactions without their required evidence.
Produce actions that change the operating process
Record the review date, scope, participants, evidence examined, findings, actions and responsible owners. Give each material action a completion date and an effectiveness check. Rewriting a form may close an administrative task without preventing the underlying failure. Where a weakness affects current goods, consider release holds or other immediate measures while the long-term correction is implemented.
Assess whether findings affect products already placed. A discovered unknown source, false record or relevant rights issue may engage the operator's immediate Article 4(5) notification obligations. Do not wait until the annual review report is approved to handle information requiring prompt action. Keep the operational concern process available throughout the year.
Use the current Articles 10 to 12 as the legal baseline. Preserve the updated system and the history of changes, then communicate relevant changes to the people using it. A useful review ends with evidence that the system now handles identified risks more reliably, alongside a clear record of any unresolved issues and their effect on product release.
Primary sources on the record
Articles 4(5), 10(4), 11(3), 12 and 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.