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
A product-based compliance process
EUDR due diligence is the evidence-based process an operator completes before placing a relevant product on the EU market or exporting it. Under Article 8 it comprises information collection, risk assessment and risk mitigation. Its purpose is to demonstrate compliance with Article 3, rather than simply record that a supplier has accepted a contractual sustainability clause.
Article 3 requires deforestation-free status, lawful production under the relevant legislation of the country of production, and coverage by the required due diligence statement or simplified declaration. Each condition answers a different question. A valid export permit does not establish that forest was not converted after the cut-off. A clean land-cover history does not establish rights to use the land. Submission of a statement does not make either underlying conclusion true.
The EUDR due diligence framework applies these requirements across a repeatable business process. First classify the relevant product and identify the actor's role. The current Regulation distinguishes ordinary operators from downstream operators and traders. Their obligations are not interchangeable, and the original 2023 actor model should not be used to assign an ordinary statement obligation to every business handling a product.
What the three stages mean
Information collection under Article 9 establishes what the goods are and where the relevant commodities were produced. It includes descriptions, quantities, origin, the applicable production locations and dates, supplier and business-recipient details, and verifiable evidence concerning deforestation and legality. The evidence must relate to the relevant product being handled. A supplier's general policy may provide context, but cannot identify the production plots for an unidentified shipment.
Risk assessment under Article 10 examines whether those records provide a supported compliance conclusion. It considers reliability, country and local circumstances, indigenous peoples' rights, supply-chain complexity, mixing and other prescribed criteria. The operator must document how the information was checked and how the degree of risk was determined. Possessing a document and accepting its claims are separate decisions.
Risk mitigation under Article 11 responds where the assessment does not establish no or only negligible risk. The operator may need more information, independent audits or surveys, improved segregation, or another appropriate measure. Mitigation is assessed by its result. Commissioning an audit does not permit release while its findings remain unresolved. The decision must show how the measures achieved the required risk threshold.
A practical example
Consider an importer purchasing cocoa beans from a cooperative. A usable file identifies the consignment, the producing farms, the harvest period, the quantities and the movement through the cooperative's store. It includes evidence addressing the plots' deforestation status and the applicable production laws. If an intermediary added beans from unnamed farms, an otherwise detailed cooperative register leaves a material gap.
The importer investigates the missing origins and whether the affected beans can be reliably separated. If records establish the complete source and the compliance evidence is sufficient, the assessment can be completed. If the source remains unknown and non-negligible risk cannot be reduced, the ordinary operator cannot place the relevant product on the market. A commercial discount or supplier indemnity does not fill that evidential gap.
This example also shows why due diligence is different from certification. A certificate may contribute relevant evidence, depending on its scope, reliability and connection to the goods. It does not transfer the operator's responsibility or automatically prove that every EUDR condition has been satisfied. Check what was certified, where and when, rather than relying on a logo appearing on an invoice.
Distinguish the two simplified routes
Article 13 permits simplified due diligence where all relevant production is in countries or parts classified as low risk and the required assessment of chain complexity, circumvention and mixing supports its use. This relieves the Article 10 and 11 obligations in the qualifying situation, not Article 9 information collection or the product conditions. Relevant adverse information can trigger full assessment and mitigation and immediate communication to the authority.
Article 4a is a different regime for qualifying micro or small primary operators. It changes specified statement obligations and provides a one-time simplified declaration or an eligible public-database arrangement. It does not mean every small importer uses a simplified declaration. Businesses need to establish the precise definition and factual eligibility before building a workflow around it.
Ordinary operators submit their statement only after due diligence supports compliance, and before the relevant placement or export. The statement's reference number records the submission; it is not official product approval. Businesses subject to Article 5 instead need the current downstream and trader process, including applicable information, registration and concern-handling duties.
Make the decision reproducible
An effective record shows the goods reviewed, evidence available, checks performed, concerns identified and reasons for the final decision. It identifies the responsible reviewer and connects the decision to the statement or other applicable identifier. That makes the conclusion understandable to another competent employee or an authority, even if the original buyer has left the business.
The system must remain current and receive at least annual review under Article 12. Individual risk assessments and mitigation decisions have their own at-least-annual review requirements. New information can demand action sooner. Plan for changed suppliers, new plots, altered production methods, amended legislation and substantiated concerns, rather than assuming that the first approval lasts indefinitely.
For implementation, begin with when due diligence must be completed and define the transaction's release gate. As of the verification date, the general application date is 30 December 2026, with specified later dates and exceptions. Use the current consolidated legal text to determine the rule applying to the product and actor, then retain the evidence that explains the decision.
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.