EUDR Requirements Checklist: What You Need to Comply

EUDR Compliance: What You Actually Need to Do

The EU Deforestation Regulation (EUDR) introduces strict requirements for businesses placing covered commodities on the EU market. While the regulation is comprehensive, your actual obligations depend on your role in the supply chain.

This guide breaks down exactly what you need to collect, document, and submit to maintain EUDR compliance—whether you're an operator importing goods or a trader distributing them.

Key Principle: EUDR compliance is built on three pillars: information collection, risk assessment, and mitigation. Every requirement flows from these core obligations.

Requirements for Operators vs Traders

The EUDR distinguishes between two types of economic actors, each with different compliance obligations:

Important for SMEs: Micro and small enterprises benefit from simplified due diligence procedures for products from standard-risk countries, but the core requirements remain the same.

The Due Diligence Statement (DDS) Explained

The Due Diligence Statement is the cornerstone of EUDR compliance. Every operator must submit a DDS to the EU Information System before placing products on the market.

What the DDS Contains

Your DDS is a formal declaration that includes:

• Operator details – Your company information and contact details
• Product description – Commodity type, quantity, HS code
• Country of production – Where the commodity was grown or harvested
• Geolocation data – GPS coordinates of all production plots
• Supplier information – Complete supply chain traceability
• Compliance declaration – Confirmation that products are deforestation-free and legally produced
• Risk assessment conclusion – Summary of your due diligence findings

When to Submit

The DDS must be submitted before products are placed on the EU market or exported. This means:

• Before customs clearance for imports
• Before first sale for EU-produced goods
• Before export declaration for products leaving the EU

DDS Reference Numbers for Traders

When you purchase products from an operator, request the DDS reference number immediately. This unique identifier proves the operator has fulfilled their due diligence obligations. Without it, you cannot demonstrate compliance.

Information You Must Collect

EUDR compliance begins with comprehensive data collection. Here's exactly what information operators must gather from their supply chain:

1. Product Information

2. Country and Region of Production

3. Supplier Details

4. Proof of Legal Production

The European Commission implementation guidelines provide templates and examples for each document type.

GPS Coordinates & Geolocation Requirements

One of the most challenging EUDR requirements is providing precise geolocation data for all production plots. This allows authorities to verify products weren't produced on recently deforested land.

What GPS Data You Need

You must provide coordinates that identify all plots of land where the commodity was produced. The format depends on plot size:

GPS Coordinate Format

Coordinates must be provided in decimal degrees (not degrees/minutes/seconds) using the WGS84 coordinate reference system. Example:

How to Obtain GPS Data

Your suppliers must provide this data. Methods include:

• Smartphone GPS – Most modern phones can capture coordinates (use apps like GPS Test or Coordinates)
• Handheld GPS devices – Garmin, TomTom, or agriculture-specific units
• Satellite imagery analysis – Use tools like Google Earth Pro (free) to mark plot boundaries
• Government cadastral data – Some countries maintain digital land registries with coordinates
• Certification bodies – FSC and other certifiers often have GPS data on file

Special Cases

• Multiple plots: If your commodity comes from multiple farms, you need GPS data for each plot.
• Mixed batches: If a shipment contains products from different sources, document each source's geolocation separately.
• Unknown origin: If you cannot obtain GPS data, you cannot place the product on the EU market under EUDR.

Risk Assessment Procedures

After collecting information, operators must conduct a risk assessment to determine if there's a risk the products contributed to deforestation or illegal production.

Risk Criteria (Article 10)

Your assessment must consider these mandatory factors:

Risk Mitigation Measures

If your assessment identifies risks, you must take mitigation actions before submitting the DDS:

• Request additional information or documentation from suppliers
• Conduct or commission independent audits
• Seek third-party verification (e.g., FSC, SAN/Rainforest Alliance)
• Use satellite imagery to verify no recent deforestation
• Interview local stakeholders or NGOs
• Implement enhanced monitoring protocols

If risks cannot be adequately mitigated, you cannot place the products on the EU market. This is a hard requirement—there's no "acceptable risk" threshold.

Simplified Due Diligence for SMEs

Micro and small enterprises sourcing from low-risk countries may use simplified procedures, such as relying more heavily on third-party certifications and less on custom audits. However, the basic information collection requirements remain unchanged.

Record-Keeping Requirements

Both operators and traders must maintain comprehensive records for at least 5 years from the date of placing products on the market or making them available.

What to Keep

How to Organize Records

Authorities can request records at any time during inspections. Best practices:

• Digital storage: Use cloud-based systems with backup (local paper files are risky)
• Indexing: Organize by shipment date, supplier, or DDS reference number
• Access controls: Limit who can edit or delete records (audit trail required)
• Regular reviews: Quarterly checks to ensure nothing is missing
• Retention alerts: Set calendar reminders before the 5-year expiration

Your Complete EUDR Compliance Checklist

Use this actionable checklist to ensure you've covered all EUDR requirements. Download a printable PDF version below.