How EUDR due diligence fits together

From records to a decision

Article 8 describes the due diligence framework through information collection, risk assessment and risk mitigation. The purpose is to reach and support a decision about the relevant products. A folder containing invoices and maps is only a starting point.

First confirm the product scope and your legal role. The standard operator process, simplified due diligence and the micro or small primary operator regime have different conditions. Do not treat a workflow diagram as a universal filing instruction.

Collect information that can be checked

Article 9 identifies information including product description, quantity, production country, production locations, production date or range, supply-chain contacts, and evidence addressing deforestation-free and legal production. The records must relate to the actual goods under review.

Give each record an owner, source and date. Suggested quality checks include matching plot identifiers across files, confirming that production periods align with the shipment, and investigating contradictory supplier records.

Assess and resolve risk

Risk assessment examines the collected information against the Article 10 criteria. Country classification is one input. Supply-chain complexity, reliability of evidence, mixing and relevant concerns also matter. Where risk is more than negligible, Article 11 calls for adequate mitigation before market placement or export.

Document the issue, the measure taken, the resulting evidence and the revised conclusion. Repeating a supplier declaration without resolving the underlying uncertainty is not a useful mitigation record.

Keep the release decision connected

For the standard operator route, the due diligence statement follows the required assessment and must be available before the relevant placing on the market or export. The information-system submission does not itself prove that the supporting assessment was sound.

Retain a traceable link from the release decision to the product, evidence and statement reference. Article 12 requires retention of due diligence documentation for at least five years and maintenance of the system. The risk assessment and mitigation guide develops the review stage.

Suggested preparation checklist

• Assign product and supplier identifiers.
• Record scope and role decisions.
• Collect source-linked evidence.
• Resolve gaps before release.
• Preserve the decision history and associated references.