EUDR compliance checklist for operators and traders

This article is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for advice specific to your situation.

What this checklist covers

This is a working checklist for the businesses regulated under the EU Deforestation Regulation: operators, downstream operators, and traders who need to place EUDR-covered commodities or derived products on the EU market, or export them from it. It reflects the regulation as amended by Regulation (EU) 2025/2650, published in the Official Journal on 23 December 2025, which revised the regulated-party categories, the application dates, and several due diligence obligations.

A checklist cannot substitute for legal advice on a specific supply chain, and EUDR application dates, scope, and benchmarking classifications have already changed more than once since the regulation was adopted. What this checklist can do is give you a structured starting point so that nothing currently required by the regulation gets missed, and so that the scale of the task is clear before a shipment deadline forces the issue.

The full explanation of what the regulation requires and why is covered in EUDR explained: what the EU Deforestation Regulation requires and who it affects. This article assumes that background and focuses on the operational sequence.

Step 1: Confirm your classification under the amended regulation

Your obligations differ significantly depending on which category you fall into, and the amended regulation now has four categories. This has to be settled first.

• Confirm whether your company is placing a relevant commodity or product on the EU market for the first time, or exporting it from the EU. If so, you are an operator and bear the full due diligence obligation, including submission of the due diligence statement.
• Confirm whether your company is a micro or small primary operator: a natural person or micro or small enterprise established in a low-risk country who places on the market or exports relevant products you yourself produced. If so, you may submit a one-time simplified declaration rather than a full due diligence statement per consignment.
• Confirm whether your company places on the market or exports a product made by processing another relevant product that has already been covered by a due diligence statement or simplified declaration further up the chain. If so, you are a downstream operator, introduced by the 2025 amendment. Your obligations are identical to those of traders: you do not submit your own due diligence statement, but must register in the EU information system. If you are the first downstream operator in the chain, you must also collect and retain the upstream reference number.
• Confirm whether your company makes a relevant product available on the EU market without processing it and without being the first to place it there. If so, you are a trader. Your obligations are identical to those of downstream operators.
• Where your company plays more than one role across different product lines, map this out by product line rather than assuming one classification applies across the business.

Use the EUDR commodity & country checker to see the specific obligations and country risk tier for any commodity and source country combination.

Step 2: Confirm which products are in scope

The breadth of derived products catches many businesses by surprise. Confirm scope before doing anything else.

• Check each product line against the seven commodity groups: cattle, cocoa, coffee, palm oil, soya, wood, and rubber.
• Check derived products against Annex I to the regulation, not just the raw commodity. A processed food, cosmetic, or furniture item containing one of the seven commodities as an input may be in scope even though it does not resemble the raw material.
• If your product line includes printed materials such as books or newspapers, confirm that these have been removed from scope by the 2025 amendment and do not require due diligence on that basis alone.
• For composite or multi-ingredient products, identify every in-scope commodity used as an input, not just the primary one. A product can draw on more than one EUDR commodity at once, for example a confectionery item using both cocoa and palm oil.
• Confirm the HS code classification used for customs purposes for each product line, since this is typically the practical reference point used to determine EUDR applicability at the border.
• Document the scope determination for each product line, including the reasoning, so the conclusion can be revisited if Annex I is amended again or if a product’s composition changes.

Step 3: Identify your applicable deadline

The application dates have been postponed twice since the regulation was adopted. Confirm you are working from the current dates, not an earlier version.

• Confirm whether your company qualifies as a medium or large operator, trader, or downstream operator, or as a micro or small enterprise, under the regulation’s size criteria.
• If medium or large, confirm that obligations apply to your company from 30 December 2026.
• If micro or small, confirm that obligations apply from 30 June 2027.
• If you previously built systems around the earlier 30 December 2025 or 30 June 2026 dates, confirm those systems are still on track for the revised dates and have not been deprioritised on the assumption that the postponement removes the need to prepare.
• Do not treat either deadline as a reason to delay starting the data collection work in Step 4. That work cannot be completed quickly once started, and a further simplification review is due from the Commission by 30 April 2026, which may affect requirements again before the application dates arrive.

Step 4: Collect the required information for each product

This is the core data collection task and the one most likely to expose gaps in your supply chain’s existing recordkeeping. It applies in full to operators. Downstream operators and traders should confirm with their suppliers that this information has been collected and is available on request, rather than collecting it independently.

• Collect a description of the product, including the commodity, quantity, and country of production.
• Collect plot-level geolocation data for every parcel of land where the commodity was produced. For cattle products, collect the coordinates of every establishment where the animals were kept.
• Confirm that geolocation data identifies the actual production land, not a village, cooperative office, or regional centroid. Coordinates that do not correspond to the real plot will not pass verification.
• Collect evidence or a substantiated statement that the land was not subject to deforestation or forest degradation after 31 December 2020.
• Where satellite monitoring data is the basis for this determination, confirm which monitoring source was used and that it covers the relevant time period and location accurately.
• Collect a legal compliance statement confirming that the commodity was produced in accordance with the relevant legislation of the country of production, covering land use rights, environmental protection, and applicable labour law.
• Confirm that the legal compliance statement is substantiated with supporting documentation rather than asserted as a bare statement.
• Collect the names and contact details of supply chain actors sufficient to trace the product from the point of placing it on the EU market back to the production land.
• Where the supply chain involves intermediaries, such as collection points, cooperatives, or mills, confirm that each handover point is documented in a way that preserves the link to the original plot.

Step 5: Carry out the risk assessment

This step applies to operators. Downstream operators and traders are not required to repeat the risk assessment already carried out upstream, but should understand it well enough to know what they are relying on.

• Check the benchmarking classification (low, standard, or high risk) for the country and, where applicable, the region of production.

The EUDR country & commodity checker shows current risk tiers for all 34 major source countries across all seven commodities.

• Where the classification is low risk, confirm whether your company is using the simplified due diligence option, or, for micro and small primary operators, the simplified one-off declaration, and document why.
• Where the classification is standard or high risk, confirm that full risk assessment has been carried out rather than relying on the simplified approach.
• Assess the presence of forests in the area of production and the deforestation risk this implies.
• Assess the complexity and length of the supply chain, including how many intermediary steps exist between the production plot and the point of placing the product on the EU market.
• Assess the reliability of the documentation provided by suppliers, including whether previous submissions from the same supplier have required correction or follow-up.
• Check for any third-party concerns, including reports from NGOs, civil society organisations, or public bodies, about the specific area or supply chain in question.
• Record the outcome of the risk assessment for each product and supply chain, including the specific factors that led to the risk classification reached.

Step 6: Apply risk mitigation where required

This step applies to operators carrying out full due diligence.

• Where the risk assessment identifies a non-negligible risk, determine what mitigation measures are appropriate before proceeding. This may include requesting additional documentation, commissioning an independent audit of the production site, or working with the supplier to implement ongoing monitoring.
• Document the mitigation measures taken and the reasoning behind selecting them.
• Where a risk cannot be mitigated to an acceptable level, confirm internally that the product will not be placed on the EU market, and record that decision.
• Where mitigation depends on supplier cooperation, such as providing further documentation or submitting to an audit, track this as an open item with a deadline rather than leaving it unresolved while the shipment proceeds.

Step 7: Fulfil your due diligence statement obligation according to your classification

This step now differs sharply by category. Confirm which version applies to you before proceeding.

• If you are an operator: confirm that your company has access to and is registered on the EU information system, and submit the due diligence statement (or, where eligible, the simplified one-off declaration) before placing the product on the EU market or exporting it.
• If you are an operator: record the reference number generated by the submission and ensure it is communicated to downstream operators and traders as the product moves through the supply chain.
• If you are a downstream operator or trader: confirm that you are registered in the EU information system. You are not required to submit your own due diligence statement under the amended regulation.
• If you are a downstream operator or trader: collect and retain the due diligence statement (or simplified declaration) reference number from your supplier, and verify that the underlying statement has in fact been submitted rather than accepting an assurance that it has been done.
• If you are a micro or small primary operator sourcing from a low-risk country: confirm whether the simplified one-off declaration has been submitted, and check whether relevant information is already available through a Member State database that removes the need for further action on your part.

Step 8: Maintain records

• Retain the underlying documentation, including geolocation data, supplier declarations, risk assessments, and mitigation records, for a minimum of five years. This applies regardless of classification.
• Store the documentation in a format and location that allows it to be produced promptly if a competent authority requests it during an inspection.
• Confirm that records are organised at consignment level, so that a specific shipment can be traced back to its supporting documentation without having to reconstruct the link after the fact.
• If you are a downstream operator or trader, confirm that your records clearly show the chain of due diligence statement reference numbers linking your product back to the original operator submission.
• Establish a process for retaining records when supplier relationships end or when a supply chain is restructured, so that historical documentation is not lost.

Step 9: Monitor for changes that affect your compliance position

EUDR compliance is not a one-time exercise, and the regulation itself has changed twice since adoption. The following should be checked on an ongoing basis rather than only at the point of initial compliance.

• Monitor for changes to the benchmarking classification of countries or regions you source from. A reclassification from standard to high risk increases the due diligence burden going forward.
• Monitor for the Commission’s simplification review, due by 30 April 2026, and any legislative proposal that follows it, since this may further amend due diligence obligations before the current application dates arrive.
• Monitor for new guidance or implementing rules published by the European Commission that may affect how due diligence obligations apply to your sector or commodity.
• Reassess supply chain risk when sourcing from a new supplier, a new region, or a new intermediary, rather than relying on a risk assessment conducted for a different part of the supply chain.
• Reassess existing suppliers periodically rather than treating an initial due diligence pass as permanently valid, particularly for suppliers in regions with active deforestation risk.

Where this checklist fits with building the underlying system

This checklist sets out what needs to be done. It does not address how to build the data collection, verification, and documentation infrastructure that makes completing it possible at scale, particularly for supply chains involving large numbers of smallholder suppliers. That operational build-out is covered in How to build an EUDR due diligence system from scratch.

For commodity-specific detail on where the practical difficulties tend to concentrate, see the dedicated articles on palm oil, cocoa, and timber and wood products.

Verdandi monitors EUDR developments continuously, including country benchmarking classifications and implementing guidance, so the system you build is anchored to the current requirements rather than a snapshot that goes stale. Start for free.