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 11
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
Request information that follows the supply chain
An EUDR operator needs supplier information that connects the purchased relevant product to its production origins and to evidence of deforestation-free status and lawful production. Supplier onboarding records alone cannot do this. The request should distinguish the legal selling business, intermediaries, actual producers, production plots or cattle establishments, and the goods supplied in the particular transaction.
Article 9 specifies the operator's required information. A supplier may provide much of it, but the operator must verify and analyse the evidence under the applicable due diligence process. An email saying all information is available on request does not mean the evidence was collected before release. Agree when, in what format and through which responsible person the information will be delivered.
The operator's due diligence system should adapt requests to the supply structure. A direct farmer relationship differs from sourcing through an exporter that aggregates hundreds of farms. Ask each participant for information they can substantiate. If an intermediary promises that its upstream suppliers retain the records, establish how the operator can obtain and evaluate the necessary evidence.
Build a clear supplier request
Identify the product's trade name and type, quantities and applicable units, relevant commodities or products used, and common and full scientific species names for relevant wood. Request stable supplier product identifiers alongside your own stock codes. This prevents a document for a similarly named grade from being attached to the wrong product specification or shipment.
Request the country of production, relevant country subdivisions, all applicable production locations, and production dates or time ranges. Specify that shipment origin is not the same as production origin. For non-cattle commodities, explain the plot information needed; for cattle-related products, address the required establishments. Where a narrow Article 4a exception is relevant, verify it rather than instructing every small supplier to provide only an address.
Obtain the supplier's name, postal address and email address and keep those separate from producer identities. Ask how the supplier connects origins to each consignment, including aggregation, processing, storage and onward dispatch. The most useful response may be a set of linked records rather than one general declaration signed by a sales representative.
Specify evidence quality without inventing universal documents
Ask for evidence addressing the deforestation-free condition and the relevant legislation of the production country. Describe the question each record should answer. Historical land-cover evidence should concern the actual locations and relevant periods. Legal-production evidence should identify the applicable right, activity, holder and area. An authentic document about a different farm cannot support the intended goods.
Avoid demanding one universal list of permits from all countries. Land-use rights may arise through different legally recognised arrangements, and the Regulation's legality framework covers more than land title. Determine what rules apply in the production circumstances, then ask for appropriate verifiable information. A blanket request for a land deed could exclude relevant lawful arrangements while overlooking labour or third-party rights issues.
Make verification practical. Request readable originals or reliable copies, issuing bodies, validity periods and identifiers where relevant. Preserve translations and explanations alongside the source. A translation can assist review, but unexplained differences in a name or parcel number need resolution. If commercial confidentiality is raised, agree secure evidence access rather than assuming confidentiality removes the operator's duty.
Ask about changes and mixing
The supplier should explain whether it can replace producers or source from spot markets without notice. A contract limited to a named supplier does not prevent that supplier from changing farms. Request notification of new origins, altered plot boundaries, changed production periods, new processors and relevant concerns. Define which changes require prior acceptance for the operator's release process.
Ask how goods are kept identifiable where compliant and unresolved material are stored together. This is especially important for mills, bulk stores and aggregators. A system that records how much approved material entered a facility may still fail to show whether the actual delivered lot contains unknown material. Obtain evidence of the physical or otherwise legally sufficient traceability arrangement being relied upon.
For example, a cocoa supplier may send a complete farm register at onboarding but later purchase extra beans through a village intermediary. The operator needs to know whether those beans entered its lot and whether their sources are documented. The supplier-change procedure should cover this origin change even though the invoicing company remains the same.
Evaluate responses and preserve the relationship
Review the package for gaps and contradictions before asking for another signature. Coordinates outside the declared country, dates after dispatch, or quantities inconsistent with production capacity point to specific follow-up questions. Tell the supplier exactly which relationship is unclear. Repeatedly sending the same generic questionnaire often reproduces the same incomplete response without improving evidence.
Use contracts to support cooperation, access, change notification and correction, while recognising that contractual warranties do not establish compliance. Supplier training and capacity building can help smaller producers supply reliable information. Article 11 recognises such support as a possible mitigation measure. The operator still needs to assess whether the resulting evidence resolves the relevant risk before release.
Keep a dated record of requests, responses and verification, connected to the products and shipments covered. Article 9 evidence has a five-year retention period from placement or export, even if the supplier relationship ends. Check the current Articles 9 to 11 when updating your request template. A useful supplier file explains both the supplier's claims and the operator's reasons for relying on them.
Primary sources on the record
Articles 4 and 8 to 11. 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.