In order to keep selling goods containing listed products to your customers in the EU, your business needs to set up an EUDR Due Diligence System to demonstrate that your products are:
The Due Diligence System is a framework of procedures, controls and records that your business will use to demonstrate compliance with EUDR. In this article, we outline the key elements of an EUDR Due Diligence System to help you make sure that your business is ready ahead of the December 30th deadline.
Your Due Diligence System should contain procedures documenting how your business:
If your business already has a system of Standard Operating Procedures (SOPs), incorporating EUDR compliance procedures into this system is often the most streamlined way to develop your EUDR Due Diligence System. Alternatively, you can create a set of standalone EUDR compliance procedures.
Due Diligence Statements are the means by which businesses demonstrate that every consignment of their product containing listed products placed in the EU market complies with EUDR. The Due Diligence Statement contains information about the product being placed on the EU market, including country and geolocation of production, supply chain information and a declaration that the product carries no, or negligible risk, of contributing to deforestation. Whenever your business sells goods containing listed products to a company in the EU, you must file a Due Diligence Statement with that country's Competent Authority using the EU'S TRACES portal.
If your business is buying directly from a producer, your company will need to prepare the Due Diligence Statement from scratch to be able to place the product on the EU market. The buyer, not the producer, is the entity legally responsible for generating the Due Diligence Statement.
If you are buying listed products from an intermediary company in the EU, a Due Diligence Statement should be provided as part of the sale. If you are buying from an intermediary outside of the EU, your supplier may not be able to provide a Due Diligence Statement, in that case, your supplier must provide the geolocation of the product.
It is important to work with your supply chain ahead of December 30th, 2025 to ensure that your suppliers of listed products will be able to provide Due Diligence Statements and/or geolocation files. When filing a Due Diligence Statement for your product, you should reference the Due Diligence Statement reference numbers of all in scope raw materials.
You must assess the risk of your raw materials being non-compliant with local laws or originating from an area that has been subject to deforestation or forest degradation after December 2020. The European Commission provides country specific risk benchmarking you can use to help with this. You should also assess your supply chain, taking into account any historical failure to comply with EUDR or evidence of corruption.
If your initial risk assessment is not able to show a negligible risk of non-compliance, you must take, and document, mitigations. Common early stage mitigations are to close data gaps by requesting additional data from suppliers or independent auditors to demonstrate that the material is in compliance with EUDR.
If these mitigations are insufficient to move the risk of non-compliance with EUDR to negligible, you can not place your goods on the EU market and may wish to establish corrective actions with your supply chain or exclude certain suppliers to ensure you will be able to continue to trade in the EU.
To comply with EUDR, you must keep a record of all Due Diligence Statements filed, any training provided to staff and any updates to your procedures for at least five years. Any Competent Authority may audit your business to ensure compliance and they will request five years worth of records.
Auditors will also wish to see evidence that you have tracked your product from field to the point of sale and evidence of your risk assessments and any third party verification you have had conducted. Large companies must also publish an annual report on their Due Diligence System showing how they have exercised due diligence and documenting the steps they have taken to ensure compliance with EUDR.
For help getting a Due Diligence System in place ahead of December 30th, 2025, contact us today!
Find out what your business needs to do to put an EUDR compliant Due Diligence System in place.
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In June 2023, the EU Regulation on Deforestation-free Products, or EUDR, was written into law. From December 30th, 2025 businesses selling commodities linked to deforestation to customers in the EU will be required by this law to prove that they have not contributed to new deforestation or forest degradation. Read on to find out if your business needs to comply with EUDR.
