The EU Deforestation Regulation (EUDR) Due Diligence Statement is a mandatory compliance document required under Regulation (EU) 2023/1115 that obliges operators and traders placing specific commodities on the European Union market to demonstrate that these commodities are deforestation-free and legally produced. This statement must include detailed geolocation data, risk assessments, and verification steps, submitted through the official EUDR information system before market placement.
EUDR Due Diligence Statement: How to Prepare and Submit
The EU Deforestation Regulation (EUDR) (Regulation (EU) 2023/1115) requires all operators and traders who place commodities linked to deforestation on the EU market to prepare and submit a comprehensive due diligence statement. This statement confirms that the commodities and derived products are deforestation-free and comply with the legal frameworks of the country of origin. The due diligence statement is a critical compliance document to avoid penalties of up to 4% of EU annual turnover, confiscation of goods, and temporary market exclusion.
This guide provides a step-by-step checklist to prepare and submit your EUDR due diligence statement, including geolocation data requirements, risk assessment procedures, and submission via the EU TRACES NT platform.
Who Must Submit an EUDR Due Diligence Statement?
The due diligence obligation applies to:
- Operators — entities that first place EUDR commodities or derived products on the EU market.
- Traders — entities that buy or sell these commodities within the EU market.
The scope covers the following EUDR commodities and their derived products:
- Cattle and derived products (e.g., leather)
- Cocoa and chocolate
- Coffee
- Palm oil and palm oil derivatives
- Soya and soya derivatives
- Wood and wood products (e.g., furniture, paper)
- Rubber and rubber products (e.g., tyres)
To confirm if your products fall under EUDR, check the Combined Nomenclature (CN) codes listed in Annex I of Regulation (EU) 2023/1115.
Key Deadlines for EUDR Due Diligence Statement Submission
| Entity Type | Deadline to Submit Due Diligence Statement | Applicable Regulation Reference |
|---|---|---|
| Large Operators (≥ 250 employees or ≥ €40 million turnover) | 30 December 2025 | Regulation (EU) 2023/1115, Article 31 |
| Small and Medium-sized Enterprises (SMEs) | 30 June 2026 | Regulation (EU) 2023/1115, Article 31 |
Failure to submit the due diligence statement by these deadlines will expose operators and traders to enforcement actions including fines and market restrictions.
Step-by-Step Guide to Preparing Your EUDR Due Diligence Statement
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Identify EUDR Commodities in Your Supply Chain
Review your product portfolio against the CN codes in Annex I of Regulation (EU) 2023/1115. Only commodities and derived products listed are subject to EUDR due diligence. -
Collect Geolocation Data for Production Sites
For each plot of land where the commodity was produced, collect precise GPS coordinates as polygons or points, along with the date of production. This data is essential to verify deforestation status. -
Verify No Deforestation After 31 December 2020
Use satellite monitoring data or trusted third-party verification to confirm that the land was not deforested after the EUDR cut-off date of 31 December 2020. -
Confirm Compliance with Local Legislation
Verify that the commodity was produced in accordance with the applicable laws of the country of production, including land tenure and environmental regulations. -
Conduct a Risk Assessment
Classify the country of origin as low, standard, or high risk based on the European Commission’s country benchmarking published under EUDR. This classification determines the level of due diligence required. -
Implement Risk Mitigation Measures
For commodities from standard or high-risk countries, apply additional risk mitigation measures such as enhanced supplier audits or alternative sourcing. -
Submit the Due Diligence Statement
Upload the completed due diligence statement via the EUDR information system, specifically the EU TRACES NT platform, before placing goods on the EU market. -
Maintain Records for Five Years
Retain all documentation, geolocation data, risk assessments, and verification reports for a minimum of five years to demonstrate compliance during audits.
Penalties for Non-Compliance with EUDR Due Diligence Statement Obligations
| Type of Violation | Potential Penalty | Legal Reference |
|---|---|---|
| Failure to Submit Due Diligence Statement | Fine up to 4% of EU annual turnover | Regulation (EU) 2023/1115, Article 34 |
| Placing Commodities Linked to Deforestation on the Market | Confiscation of goods and temporary market exclusion | Regulation (EU) 2023/1115, Article 35 |
| Providing False or Misleading Information | Administrative fines and potential criminal sanctions under national law | Regulation (EU) 2023/1115, Article 36 |
Penalties are enforced by EU Member States’ competent authorities and can have significant financial and reputational impacts.
Practical EUDR Due Diligence Compliance Checklist
- ✔ Confirm if your products contain EUDR commodities using Annex I CN codes.
- ✔ Collect accurate geolocation data (GPS polygons or points) and production dates for each plot.
- ✔ Verify no deforestation occurred after 31 December 2020 using satellite or third-party data.
- ✔ Ensure compliance with the legislation of the country of production.
- ✔ Perform country risk classification using the European Commission’s published benchmarks.
- ✔ Apply risk mitigation measures for standard and high-risk countries.
- ✔ Submit the due diligence statement via the EU TRACES NT platform before market placement.
- ✔ Retain all records and documentation for at least five years.
Truth Anchor: Under Regulation (EU) 2023/1115, operators must submit their first due diligence statements by 30 December 2025 for large operators and by 30 June 2026 for SMEs, with penalties for non-compliance including fines up to 4% of EU annual turnover (Article 34).
Frequently Asked Questions
1. What exactly is a due diligence statement under the EUDR?
A due diligence statement is a formal declaration submitted by operators and traders confirming that the commodities they place on the EU market are deforestation-free, legally produced, and comply with all EUDR requirements, including geolocation data and risk assessments.
2. Which commodities require a due diligence statement?
The EUDR applies to cattle, cocoa, coffee, palm oil, soya, wood, rubber, and all derived products such as leather, chocolate, furniture, paper, and tyres. Check Annex I of Regulation (EU) 2023/1115 for exact CN codes.
3. How do I collect geolocation data for my commodities?
You must obtain GPS coordinates (either polygons or points) for each plot of land where the commodity was produced, along with the production date. This data can be collected from suppliers or through satellite mapping technologies.
4. What if my commodity comes from a high-risk country?
If the country of origin is classified as high risk by the European Commission’s benchmarking, you must implement enhanced risk mitigation measures such as additional supplier audits or alternative sourcing strategies before submitting your due diligence statement.
5. Where and how do I submit the due diligence statement?
All due diligence statements must be submitted electronically via the EU TRACES NT platform, the official EUDR information system, before placing goods on the EU market.
6. How long must I keep records related to the due diligence statement?
Operators and traders must retain all relevant documentation, including geolocation data, risk assessments, and verification reports, for a minimum of five years to comply with audit and enforcement requirements.
Ready to prepare and submit your EUDR Due Diligence Statement? Use our dedicated compliance tool at eudrregistry.com to streamline data collection, risk assessment, and submission via the EU TRACES NT platform. Click the link to start your compliance process now — the clock is ticking towards the 30 December 2025 deadline for large operators.