EUDR Due Diligence System — Implementation Guide

The Due Diligence System: Three Mandatory Steps

Article 8 of Regulation (EU) 2023/1115 requires operators to apply a due diligence system before placing relevant products on the EU market or exporting them. The system comprises three interdependent steps.

Step 1: Information Gathering

The first step involves collecting all information necessary to demonstrate that products are compliant. You must gather:

• Product description — trade name, scientific name of the species (for wood), customs code (CN/HS).
• Quantity — volume or weight of the product.
• Country of production — and, where applicable, administrative subdivisions.
• Geolocation of plots — GPS coordinates for plots under 4 ha, polygons for larger plots. Details on the geolocation requirements page.
• Date or time range of harvest/production.
• Supplier data — names, addresses, and contact details of all suppliers in the supply chain.
• Compliance evidence — documents proving that products comply with the legislation of the country of production and do not originate from land deforested after 31 December 2020.

This information must be retained for a minimum of 5 years from the date of placing on the market or exporting.

Step 2: Risk Assessment

Based on the collected information, you must carry out a risk assessment taking into account:

• Country risk — The European Commission will classify countries into risk categories (low, standard, high). See the risk assessment methodology for details.
• Supply chain complexity — the more intermediaries, the higher the risk.
• Prevalence of deforestation in the production area.
• Documented concerns — NGO reports, press articles, alerts from forest monitoring systems.
• Corruption risk in the country of production, based on international indices.
• Reliability of certifications — if the supplier holds certifications, these can reduce risk but do not eliminate the due diligence obligation.

If the assessment concludes that the risk is negligible, you can proceed directly to submitting the due diligence statement. If the risk is greater than negligible, you must proceed to step 3.

Step 3: Risk Mitigation

When the identified risk is not negligible, the operator must apply mitigation measures until the risk becomes negligible:

• Requesting additional information from suppliers — additional documents, audits, satellite imagery.
• Independent verification — on-site audits, remote sensing data analysis, consulting public databases (Global Forest Watch, JRC).
• Source diversification — changing suppliers or sourcing areas if the risk cannot be sufficiently reduced.
• Ongoing monitoring — periodic checking of deforestation alerts for production areas.

If, after applying all mitigation measures, the risk remains greater than negligible, the product cannot be placed on the EU market.

The Due Diligence Statement

After completing all three steps, the operator submits a due diligence statement in the EU Information System. This confirms that due diligence has been exercised and that the risk has been assessed as negligible. Each statement receives a unique reference number, which must be communicated to downstream buyers and customs authorities.

For a complete overview of the statement and the Information System, see EUDR.live — Information System.

Trader Responsibilities

Traders who are not SMEs have the same obligations as operators. SME traders have simplified obligations — details on the SME guide page.