EUDR Due Diligence: The Statement, Geolocation and Country Risk Process

The EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) requires companies placing cattle, cocoa, coffee, oil palm, rubber, soya, wood or listed derived products on the EU market to submit a Due Diligence Statement (DDS) per consignment through the EU's TRACES NT system. Each DDS is built on three steps — gathering product and geolocation information, assessing risk against an EU country benchmark, and, where risk is not negligible, applying mitigation measures — before the goods can legally enter or be sold in the EU market.

Deforestation-linked commodities are one of the largest sources of forest loss the EU imports indirectly through its supply chains. The EUDR was designed to close that gap by making due diligence a legal precondition for market access, not a voluntary certification exercise. For compliance, quality and procurement teams, that shift changes what "traceability" means in practice: it is no longer enough to know a supplier's country of origin — you need the exact plot of land the commodity came from, evidence it was not grown on land deforested after 31 December 2020, and proof it was produced legally under the laws of the country of production.

This article walks through the real due diligence process as it is structured under the regulation, not as a certification-style checklist. It covers scope, the three-step DDS process, the geolocation and polygon requirements, the country risk classification system, and the current application timeline — which has already been delayed twice and should be verified before you rely on it for planning.

What Falls Under EUDR Scope

EUDR covers seven "relevant commodities": cattle, cocoa, coffee, oil palm, rubber, soya and wood. The regulation does not stop at raw commodities — it also covers a defined list of derived products made from them. Practical examples include leather (from cattle), chocolate and cocoa preparations (from cocoa), furniture and paper products (from wood), and palm oil derivatives used across food, cosmetics and industrial applications. If your business imports, processes, manufactures with, or places on the EU market any product on the regulation's commodity or derived-product list, EUDR due diligence obligations apply to you as an "operator" (the first to place the product on the market) or a "trader" further down the chain.

This scope has a practical implication that many manufacturers underestimate: a company that never imports raw cocoa or timber directly can still be in scope if it buys furniture, packaging board, or leather components from outside the EU. Mapping which of your purchased inputs fall under the commodity list is the first compliance task, well before any geolocation data is collected.

The Three-Step Due Diligence Statement Process

EUDR due diligence is not a document you file once. It is a per-consignment process built around three sequential steps, each of which feeds into the DDS submitted through TRACES NT before goods reach the EU market.

Step 1 — Information Gathering

The operator must collect and hold specific information for each consignment: a description of the product (including its commodity code), the quantity, the geolocation coordinates of every plot of land where the commodity was produced, supplier and country-of-production details, and documentary evidence that the commodity is both deforestation-free and legally produced under the laws of the country of origin. This is the evidentiary backbone of the whole process — without complete, accurate plot-level data, the risk assessment step cannot be performed correctly.

Step 2 — Risk Assessment

The information gathered in step one is then evaluated against three factors: the EU's country/region risk benchmark (covered in detail below), risk factors specific to the commodity in question, and the complexity of the supply chain — for example, how many intermediaries sit between the plot of production and the operator. The output of this step is a determination of whether the risk of non-compliance is negligible or not.

Step 3 — Risk Mitigation

If the risk assessment does not conclude that risk is negligible, the operator must apply additional risk mitigation measures — further verification steps, additional evidence requests, or independent checks — before the commodity can be placed on the market. Only once risk has been reduced to negligible can the DDS be finalised and submitted. This is where the country risk classification (below) has the biggest practical effect: it determines whether this step is required at all.

Each DDS is submitted per consignment through the EU's TRACES NT system, the same platform the EU already uses for sanitary and phytosanitary trade controls. In practice, this means due diligence is not a one-off annual exercise — it is a recurring, per-shipment compliance step that has to be embedded into procurement and logistics workflows, not bolted on at year-end.

Geolocation and Traceability Requirements

EUDR's most operationally demanding requirement is plot-level geolocation. Every production plot linked to a consignment must be identified with coordinates or polygon geometry, recorded in the WGS 84 coordinate reference system.

• Plots larger than 4 hectares require full polygon geometry — the actual boundary shape of the land, not just a centre point.
• Plots 4 hectares or smaller can be identified with a single point (a single coordinate pair).

This is the requirement that most exposes fragmented or informal supply chains: collecting a single GPS point from a smallholder is manageable, but collecting accurate polygon geometry for larger estates — and keeping that data current as land use changes — requires either supplier cooperation, satellite/remote-sensing verification, or both. For manufacturers several tiers removed from the plot of production, this data has to be pushed back up the supply chain contractually; it cannot be reconstructed after the fact.

Country Risk Classification: Standard, Low and High

The EU operates a benchmarking system that classifies countries — and, more precisely, country-commodity pairs — into low, standard or high risk categories. This classification is what step two of the due diligence process is measured against, and it has a direct, practical consequence for how much work step three requires.

Low-risk classification allows operators to apply simplified due diligence: the risk assessment and risk mitigation steps can be skipped, provided the information-gathering step has still been completed in full. Standard-risk and high-risk classifications require the complete three-step process, including any mitigation measures the risk assessment determines are necessary.

Because this benchmark is set and maintained by the EU at country-commodity level rather than as a single blanket score per country, the same country can carry a different risk classification for, say, coffee versus wood. Compliance teams need to check the current benchmark for each commodity-origin pair they source from, rather than assuming a single country-wide risk rating applies across every product line.

Enforcement Timeline — Currently Scheduled, Subject to Change

EUDR's application date has already been postponed twice since the regulation was adopted. As currently scheduled, under Regulation (EU) 2025/2650 (published in the Official Journal on 23 December 2025), the regulation is set to apply from 30 December 2026 for large and medium operators, and from 30 June 2027 for micro and small operators.

Given this history of delay, treat these dates as the current official position rather than a certainty. Before using them for internal planning, budget approval, or supplier contract deadlines, verify the current status directly against the European Commission's EUDR pages or the Official Journal — a further change to the timeline is not something this article can rule out.

Practical Impact for Manufacturers and Industrial Buyers

For manufacturing and industrial businesses, EUDR compliance is less a legal filing exercise and more a data engineering problem. The DDS process depends on complete, accurate, per-consignment records: plot coordinates, supplier chains, legality evidence and risk assessment outcomes, all of which need to be retrievable quickly and consistently — not scattered across supplier emails, spreadsheets and PDF certificates.

This is precisely the kind of document-retrieval challenge IgeraIndustria is built for. Rather than manually searching through supplier files, geolocation records and compliance evidence every time a consignment needs a DDS, IgeraIndustria lets compliance and quality teams query their own document base directly — asking, for example, which supplier certificates are on file for a given plot, or what evidence supports a legality claim — and get an answer that cites the exact source document, not a generic summary. That traceability-by-citation is what turns a recurring per-consignment obligation into a process a small compliance team can actually keep up with.

Common Mistakes to Avoid

• Treating EUDR as a certification, not a process. A sustainability certificate is supporting evidence, not a substitute for the DDS submission and the plot-level data behind it.
• Assuming low-risk status applies across all commodities from a country. The benchmark is set per country-commodity pair — verify it for each product line, not once for the whole supplier relationship.
• Collecting a single point where a polygon is required. Any plot over 4 hectares needs full polygon geometry in WGS 84 — a single coordinate is not sufficient documentation for those plots.
• Underestimating derived-product scope. Furniture, paper, leather goods and chocolate-containing products can bring a manufacturer into scope even without direct raw-commodity imports.
• Planning around the current dates as fixed. The application date has moved twice already; build in a margin and check the current status before treating 2026/2027 deadlines as final.

Frequently Asked Questions