Non-SME operator/trader

• You cannot sell or export products without verifying upstream due diligence.
• If there is no reference number, you must carry out your own due diligence: collect complete information, geolocation data, perform a risk assessment, implement mitigation measures, and submit the declaration through TRACES.

SME operator/trader

• You do not need to submit a Due Diligence Statement if one already exists, but you must retain the reference number.
• If you do not obtain it, you cannot demonstrate traceability, which may result in non-compliance.
• Formally request the reference number and supporting documentation from your supplier.

Mandatory for:

• Operators (importers, exporters, and domestic producers).
• Non-SME traders.
• Authorised representatives acting on behalf of operators.

Not mandatory for:

• SME traders.
• SME operators that only place on the market products already covered by a previous Due Diligence Statement (DDS).

The risk assessment must be carried out for each relevant product. As part of that assessment, all suppliers involved in the product’s supply chain must be taken into account.

This means:

• If a product contains raw materials from multiple suppliers, you must assess the risk associated with each source.
• If a supplier provides several different products, each product requires its own risk assessment.

1. Identify each country of origin separately, including plot information, production date, and applicable legislation.
2. Assess the risk for each origin individually. The simplified due diligence procedure cannot be applied if any origin is classified as standard or high risk.
3. Mixing is only permitted if all raw materials are deforestation-free, legally sourced, and fully traceable.
4. The Due Diligence Statement (DDS) must include all countries of origin, geolocation coordinates, risk assessments, and mitigation measures.

The documents accepted as proof of legality may vary depending on the country of production and the applicable legislation. Common examples include:

• Land-use permits (ownership documents, lease agreements, or authorisations).
• Harvesting or production licences (permits and legal declarations).
• Tax and commercial documents (invoices, customs documents, and transport records).
• Traceability evidence (geolocation coordinates, maps, and GPS data).
• Environmental and forestry certifications (e.g. FSC, PEFC, and Environmental Impact Assessments).
• Labour and social compliance documentation (including labour rights and FPIC – Free, Prior and Informed Consent, where applicable).
• Risk assessment and mitigation records (reports and audit documentation).
• Due Diligence Statement (DDS) submitted through the EU TRACES system.

A single Due Diligence Statement (DDS) may be used if all batches or shipments share the same:

• Geolocated plot of land.
• Production date or production period.
• Traceability and legality information.

The DDS must include:

• Product.
• Total quantity.
• Country of origin.
• Geolocation data.
• Production dates.
• Supplier and customer details.
• Evidence of legality and risk assessment.

If there are differences in the plot of land, country of origin, production date, or risk profile, separate Due Diligence Statements (DDSs) must be submitted.

Each Due Diligence Statement (DDS) is assigned a unique reference number, which must be included in the corresponding customs declaration.

If the same DDS covers multiple shipments, the reference number may be reused, provided that all shipments are covered by the same information and conditions set out in the original declaration.

The following are generally excluded from the scope of the EUDR:

• Recycled materials: materials that have been recovered and reprocessed for reuse.
• Second-hand products: products that have already fulfilled their original intended use and would otherwise be discarded.

Note: Certain exceptions apply.

1. Goods in transit

• The EUDR does not apply if the goods are not placed on the EU market or processed within the European Union.

2. Customs warehousing

• The EUDR applies if the goods are released from the customs warehouse and placed on the EU market.

3. Re-importation

• If the goods were already covered by a Due Diligence Statement (DDS), a simplified procedure may be applied, provided that traceability and the original supporting documentation are maintained.