This checklist covers what an EU importer of palm oil or natural rubber needs to do, and to get from suppliers, to meet the EU Deforestation Regulation. It follows the regulation's three steps (collect information, assess risk, mitigate risk) and adds the checks we see buyers miss most often: geolocation quality, chain of custody and contract terms. The full checklist is below, and you can download it as a PDF to use with any supplier.
For our own progress, see our EUDR status.
Download the PDFHow to use it
Work through sections 1 and 8 once, when you set up your EUDR process and your supplier contracts. Use sections 2 to 7 for every consignment, or every batch of consignments from the same supply base. Keep the completed checklist with your due diligence records, which must be kept for five years.
The checklist reflects Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650. The application date is 30 December 2026 for large and medium operators and 30 June 2027 for micro and small operators. Check our EUDR timeline for any later changes.
The checklist
1. Scope and your role
- List every HS code you import and check each one against Annex I of the EUDR.
- Confirm whether you are the operator (first to place the product on the EU market) or a downstream operator or trader.
- Confirm your company size category, which sets your application date: 30 December 2026 for large and medium operators, 30 June 2027 for micro and small.
- Register in the EU information system and make a test due diligence statement.
2. Information to collect for each consignment
- Product description, trade name, HS code and quantity (net weight).
- Country of production.
- Geolocation of every plot of land where the commodity was produced.
- Date or time range of production.
- Name, address and email of the supplier.
- Name, address and email of any business you supply the product to.
- Evidence that the product is deforestation-free after 31 December 2020.
- Evidence that the product was produced in line with the laws of the country of production.
3. Geolocation checks
- Coordinates use at least six decimal places.
- Plots over 4 hectares are polygons; smaller plots are points or polygons.
- The file loads in your GIS or compliance tool (GeoJSON is the format accepted by the EU information system).
- Plots fall on farmland in the stated country, not in water, towns or protected areas.
- The number and area of plots are plausible for the shipped volume.
- Each plot has been screened against forest cover at 31 December 2020, with the dataset named.
4. Legality evidence
- Land use rights, including customary tenure where formal titles do not exist.
- Environmental permits where required.
- Labour rights, including measures against child and forced labour.
- Human rights and free, prior and informed consent where relevant.
- Tax, anti-corruption, trade and customs compliance.
5. Risk assessment
- Check the country risk classification (low, standard or high) for the country of production.
- Assess forest cover and deforestation in the production area.
- Assess supply chain complexity, including smallholders and intermediaries.
- Assess the risk of mixing with products of unknown origin, at collection, processing and storage.
- Assess legality concerns, including corruption, land conflicts and labour issues.
- Record your conclusion and the reasons for it.
6. Risk mitigation (where risk is more than negligible)
- Request additional information or documents from the supplier.
- Commission independent surveys, audits or satellite checks.
- Exclude plots or suppliers that cannot be verified.
- Do not place the product on the market until the risk is negligible.
7. Filing and records
- File the due diligence statement before placing the product on the market or exporting it.
- Give the statement reference number to customs on the declaration.
- Pass the reference number to your customers where required.
- Keep due diligence records for five years.
- Review and update your due diligence system at least once a year.
8. Contract terms with your supplier
- Seller provides geolocation, legality evidence and chain of custody data for each shipment.
- Data format and delivery date are agreed, with data received before loading.
- Data matches lot numbers, quantities and HS codes on the commercial documents.
- The contract sets a remedy if data is missing, incomplete or wrong.
Where buyers most often go wrong
- Accepting mill or factory coordinates. The regulation asks for the plots where the commodity was grown. A processing site is not a plot.
- Not checking the file. A GeoJSON file that will not load, or points that fall in a river, will fail when it matters. Load every file before filing.
- Ignoring mixing. Plot data only describes your shipment if traced and untraced material were kept apart. Ask how. See geolocation and traceability data.
- Leaving EUDR out of the contract. If the contract does not require the data, the seller has no obligation to provide it on time.
- Treating low risk as no risk. Simplified due diligence still needs information and a statement. See EUDR country benchmarking.
Commodity-specific guides
- EUDR due diligence for palm oil, including mill and plot traceability
- EUDR due diligence for natural rubber, including tyres and other rubber products
This checklist is a practical aid and not legal advice. For your own obligations, take advice on the regulation as it applies to your business.