A practical step-by-step checklist for EU importers to achieve EUDR compliance. From identifying your regulated products to establishing long-term record retention — everything you need to do before enforcement begins.
The EU Deforestation Regulation (EUDR) enforcement date of 30 December 2026 is approaching fast. For operators and traders placing regulated commodities on the EU market, the time to prepare is now — not when enforcement begins. This checklist breaks down the compliance process into seven actionable steps, each with the detail you need to get started.
The first step is determining which of your products fall within the scope of Regulation (EU) 2023/1115. The regulation covers seven commodity groups — palm oil, soya, cattle, coffee, cocoa, wood, and rubber — along with a wide range of derived products listed in Annex I.
Start by reviewing your product catalogue against the Combined Nomenclature (CN) codes and Harmonised System (HS) codes listed in the regulation's Annex. These codes are the same ones used in your customs declarations, so your trade compliance or logistics team should be able to cross-reference them quickly.
Key things to check:
Create a master list of all in-scope products with their HS codes, annual import volumes, and countries of origin. This list becomes the foundation for everything that follows.
Once you know which products are in scope, you need to trace each one back to its point of production. The EUDR requires operators to know the specific plot of land where the commodity was grown, harvested, or raised — not just the country or region.
For most companies, this means going beyond Tier 1 suppliers:
Document the full chain of custody for each product. Record the names and addresses of all entities in the chain, the quantities handled at each stage, and the traceability systems in place. Pay particular attention to mixing and blending points where commodities from different origins may be combined — these are the highest-risk points for losing traceability.
For complex supply chains (common in cocoa, coffee, and palm oil), consider using a phased approach: start with your highest-volume or highest-risk supply chains and expand from there. Engage your suppliers early — they will need time to collect and share the required data.
This is often the most operationally challenging step. Article 9 of the EUDR requires the geolocation of all plots of land where the commodity was produced. The technical requirements are specific:
In practice, collecting this data means working directly with producers or their cooperatives. Many smallholder farmers in tropical regions do not have formal plot boundaries recorded digitally. You may need to support them with GPS data collection tools, mobile apps, or field mapping services.
Once collected, validate every geolocation dataset against the EUDR v1.5 specification before submission. Common errors include wrong coordinate systems, insufficient decimal precision, self-intersecting polygons, and coordinates that fall outside the declared country of origin. Automated validation tools can catch these issues before they become compliance problems.
The EUDR effectively requires satellite-based verification of deforestation-free status. While the regulation does not mandate a specific technology, satellite imagery is the only practical way to verify land-use change across thousands of production plots spanning multiple countries.
The European Commission has pointed to the Copernicus programme — the EU's own Earth observation system — as a key data source. Specifically, Sentinel-2 satellites provide:
The core analysis involves comparing vegetation indices — primarily NDVI (Normalized Difference Vegetation Index) and NDMI (Normalized Difference Moisture Index) — between a baseline period around the cutoff date (31 December 2020) and the present. A significant drop in these indices indicates potential forest loss or degradation.
You can build this capability in-house if you have remote sensing expertise, or use a compliance platform that automates the satellite analysis. Either way, ensure your monitoring covers the baseline period (June–August 2020 is commonly used for cloud-free composites) and provides clear, auditable risk classifications for each plot.
Article 10 of the EUDR requires operators to assess the risk that their products are non-compliant. This goes beyond satellite analysis — it is a holistic evaluation of multiple risk factors:
Where the risk assessment identifies non-negligible risk, you must implement risk mitigation measures before placing the product on the market. These may include requesting additional documentation from suppliers, commissioning independent field audits, switching to alternative suppliers, or engaging in supplier development programmes.
The risk assessment must be documented and retained. It forms a core part of your Due Diligence Statement and may be reviewed by competent authorities during inspections.
The Due Diligence Statement (DDS) is the formal declaration that operators must submit through the EU Information System (built on the existing TRACES NT platform) before placing regulated products on the EU market or exporting them. Each DDS must contain:
The DDS receives a unique reference number from the EU Information System. This reference number must accompany the product through the supply chain — downstream traders need it to fulfil their own obligations.
Prepare your DDS workflow well before the enforcement date. This means:
Article 12 of the EUDR requires operators and traders to retain all due diligence information for at least 5 years from the date of the Due Diligence Statement. This includes:
These records must be made available to competent authorities upon request. In practice, this means you need a document management system that is:
Consider whether your existing document management or compliance systems can handle these requirements, or whether you need a dedicated EUDR compliance platform with built-in record retention.
The seven steps above may seem daunting, but the key is to start early and take an iterative approach. Begin with your highest-volume or highest-risk supply chains. Engage your suppliers now — they need lead time to collect geolocation data and establish traceability. And invest in the right tools: satellite monitoring, geolocation validation, and DDS generation can all be automated with modern compliance platforms.
The December 2026 deadline will arrive faster than expected. Companies that have their systems, data, and processes in place will not only avoid penalties — they will have a competitive advantage as the market shifts toward verified, deforestation-free supply chains.
See how Plotwiser's AI-powered solution handles your entire due diligence pipeline.
