EUDR FAQ: Key Requirements for Non-EU Suppliers

A due diligence statement (DDS) is a formal electronic statement submitted through the EUDR Information System. It is not a certificate issued by an authority or a general supplier declaration.

The responsible operator uses the statement to confirm that due diligence has been carried out and that no or only negligible risk was found before the relevant product is placed on the EU market or exported from it.

In a common import scenario, the EU operator placing the product on the EU market is responsible for the EUDR submission. A supplier established outside the EU normally supports that process by providing accurate product, origin, geolocation, legality and traceability information.

The exact responsibility should still be checked against the transaction, the parties' legal roles and the amended EUDR provisions. A contractual request from an EU customer does not by itself change who holds the regulatory responsibility.

Depending on the product and supply chain, the information package may include:

• Product information: product description, quantity, CN or HS code and, for wood products, the common and full scientific names of the species;

• Origin information: country of production and geolocation of all relevant plots or cattle establishments;

• Production timing: the date or time range of production;

• Supply-chain records: supplier and customer information and records linking the relevant commodity to the exported product;

• Legality evidence: information showing compliance with the relevant legislation of the country of production; and

• Deforestation-free evidence: information that supports the operator's risk assessment and conclusion.

The required evidence should be matched to the product, origin, supply route and risk assessment. A generic declaration or certificate does not automatically replace the information required under EUDR.

The European Commission currently lists the following application dates:

• Large and medium operators: 30 December 2026;

• Micro and small operators: 30 June 2027; and

• Micro and small operators already covered by the EU Timber Regulation: 30 December 2026.

Non-EU suppliers should agree realistic data-delivery timelines with their EU customers before the relevant market-placement or export activity. The Regulation does not establish one universal "one to two months in advance" deadline for suppliers.

Geolocation is part of the information required for relevant commodities and products. If the required plot or establishment data cannot be obtained, the responsible operator may be unable to complete due diligence or conclude that there is no or only negligible risk.

Businesses should identify this gap early, clarify data requirements with upstream suppliers and use procurement or contractual controls where appropriate. An office address, warehouse location or village centre cannot replace the actual production location.

EUDR covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, together with the relevant products listed in Annex I of Regulation (EU) 2023/1115.

Scope should be checked against the product's CN or HS code, the Annex I description and whether the product contains, has been fed with or has been made using a relevant commodity. A product is not brought into scope solely because one of its ingredients is a relevant commodity if the finished product itself is not listed in Annex I.

It depends on how the packaging is placed on the market or exported. Annex I excludes packing material under the relevant product descriptions when it is used exclusively to support, protect or carry another product placed on the market.

However, packaging such as pallets, cases or crates may fall within scope when it is placed on the market or exported as a product in its own right. Businesses should check the applicable code, product description and actual transaction rather than relying only on the item's packaging function.

EUDR does not provide a general exemption based solely on a product's price, shipment volume or physical size. Scope depends on the relevant commodity, the product listing in Annex I and the applicable legal conditions.

Companies can use the CHEMCHECK EUDR Goods search as an initial screening tool, but the final assessment should use the current legal text and the product's verified classification.

No. The assessment must connect the Annex I product to the corresponding relevant commodity. A product code should not be assessed in isolation from the product description and the material from which the product was made.

Where a finished product contains several materials or relevant commodities, determine the commodity category under which that finished product is listed and trace the sources required for that category. Detailed multi-material examples are addressed in the separate practical DDS and traceability guide below.

The European Commission classifies countries, or parts of countries where applicable, as low, standard or high risk. The classification affects the due diligence procedure and the level of checks by competent authorities; it does not change the core requirement that relevant products must be deforestation-free and produced in accordance with relevant legislation.

Simplified due diligence may be available for products produced in low-risk countries or parts of countries when the applicable conditions are met. Low-risk classification is not an automatic exemption from collecting traceability and origin information.

Because classifications may be reviewed, businesses should confirm the country or region against the European Commission's current country classification list when conducting due diligence.