Your Complete EUDR Implementation Checklist

The clock is ticking. The EU Deforestation Regulation (EUDR) becomes mandatory for large and medium companies on 30 December 2025. That's less than six months away.

If you work with cattle, cocoa, coffee, palm oil, rubber, soy, or timber, or products derived from them, this regulation directly impacts your business.

The EUDR demands proof that your products haven't contributed to deforestation after 31 December 2020. The risks of non-compliance are high with fines up to 4% of annual turnover and products banned from the EU market.

This is your practical checklist to get EUDR right!

The Basics of EUDR

→ What: Products in Scope

Products covered by EUDR are listed in Annex I of the Regulation by their Harmonised System (HS) codes. Products containing EUDR materials but not listed in Annex I are not covered.

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→ Who: Operators vs Traders

Operators place EUDR products on the EU market for the first time or export them.

‍Their obligations include:

• Set up and maintain a Due Diligence System
• Collect supplier information and geolocation data
• Conduct risk assessments
• Implement risk mitigation measures
• Submit due diligence statements

Traders sell EUDR products already on the EU market (wholesalers, distributors, retailers).

Their obligations include:

• Store supplier's due diligence statement reference numbers
• Verify statement validity
• Maintain records for five years

The template for the due diligence statement is available in Annex XX of the Regulation.

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→ When: Implementation Timeline

Company size determines when you must comply:

• Medium and large companies: Must comply by 30 December 2025
• Micro and small enterprises: Must comply by 30 June 2026

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→ Where: Country Risk Classification

The European Commission classifies countries into three risk categories based on deforestation and legality concerns for each EUDR commodity.

• Low risk countries: The due diligence procedure is simplified: collect data but you are not required to conduct a detailed risk assessment.
• Standard risk countries: Perform full due diligence, including a thorough risk assessment and mitigation measures when necessary.
• High risk countries: Namely, Belarus, North Korea, Myanmar, and Russia. If you’re sourcing commodities from these countries, expect the need to take mitigation actions, as well as more frequent audits.

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→ How: Due Diligence Requirements

EUDR due diligence follows four mandatory steps:

1. Collect information: Trace every product back to its plot of origin. This means GPS coordinates, production dates, and supplier documentation.
2. Assess risk: Evaluate deforestation and legality risks for each product and origin. Check country risk levels, supply chain complexity, and documentation reliability.
3. Mitigate risk: Address any non-negligible risks through concrete actions. Request additional evidence, conduct field inspections, or work with suppliers to close gaps.
4. Submit Due Diligence Statement: File your declaration through the EU system confirming compliance and negligible risk. Each shipment needs its reference number.

For traders: If you're buying from operators who've already done due diligence, you simply obtain and store their statement reference numbers. Full due diligence isn't required – but verification is.

EUDR in Practice: The Coffee Supply Chain

Let's follow the journey of a bag of coffee beans from farm to shelf to understand what EUDR compliance actually looks like.

Step #1: Small Farms in Colombia

Small coffee farmers harvest their beans. They hold the original data:

• GPS coordinates of their plots
• Harvest dates
• Land permits

They're not directly covered by EUDR, but they're essential to the process.

Step #2: The Aggregator

A local aggregator collects beans from multiple farms, combining harvests for export. They must maintain traceability, knowing exactly which beans came from which plots. Still not in EUDR scope, but critical for data flow.

Step #3: The EU Importer (First-Line Operator)

Here's where EUDR obligations kick in. The importer bringing Colombian coffee into the EU must:

• Collect geolocation data for every contributing farm
• Verify no deforestation occurred after December 2020
• Assess risks (i.g. corruption, mixing with unknown sources, indigenous rights)
• Submit a due diligence statement to EU systems
• Pass their statement number to customers

Step #4: The Coffee Roaster (Downstream Operator)

A Berlin-based roaster receives the imported beans. They must verify that their supplier completed proper due diligence, then submit their own statement referencing the importer's documentation.

Step #5: The Local Café (SME Trader)

Finally, your local café sells the roasted coffee. They just need to keep records of their supplier's due diligence statement number for five years. No submission is required at this stage.

EUDR Checklist: What You Need to Do

1. Assign Ownership

☑ Designate an EUDR lead who'll drive this forward

☑ Get procurement, compliance, and logistics teams trained on requirements

☑ Secure executive buy-in and budget allocation

☑ Integrate EUDR into existing compliance frameworks

2. Define Your Scope

☑ Check every product against Annex I HS codes

☑ Identify all products containing EUDR commodities

☑ Clarify whether you're an operator (first to market) or trader (reselling)

☑ Map these materials throughout your operations

3. Understand Your Supply Chain

☑ Document all sourcing regions for EUDR commodities

☑ Assess deforestation risks by origin

☑ Start supplier conversations about GPS coordinates and harvest dates

☑ Build traceability requirements into contracts

4. Create Your Due Diligence Framework

☑ Develop standardised data collection templates

☑ Design risk frameworks covering: Country governance and corruption indices, Supply chain complexity and mixing risks, Plot-specific concerns (indigenous rights, protected areas), Documentation authenticity

☑ Set up secure systems for five-year data retention

☑ Prepare for your DDS submission

5. Use the Right Tools

☑ Evaluate satellite monitoring solutions for deforestation verification

☑ Implement supply chain mapping platforms

☑ Set up risk assessment workflows

☑ Build documentation processes that are audit-ready

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