What the EU Deforestation Regulation actually requires — the legal framework, the workflow, and the technical evidence the EU Information System expects from operators and traders.
Dexffo acts as your authorized representative — we prepare and file your DDS in EUDR Information System on your behalf, and deliver the reference number for EU customs.
01 — Scope
Regulation (EU) 2023/1115 — known as the EU Deforestation Regulation (EUDR) — prohibits placing on the EU market, or exporting from it, products linked to deforestation or forest degradation after the cutoff date of 31 December 2020.
It applies to seven commodities and their derived products: cattle, cocoa, coffee, oil palm, soy, timber, and rubber. Every shipment entering or leaving the EU under one of these commodity groups must be accompanied by a Due Diligence Statement (DDS) filed in the EU Information System.
Enforcement begins 30 December 2026 for large operators and traders, and 30 June 2027 for small and medium-sized operators (SMEs).
02 — Classification
The regulation imposes different obligations depending on whether you are placing products on the EU market for the first time, or trading products already placed.
Operator
You are placing products on the EU market or exporting them — directly or through an EU subsidiary. Most LATAM exporters fall here.
Trader
You buy and re-sell products that were already placed on the EU market by an operator earlier in the chain. SMEs have lighter obligations.
03 — Legal core
Article 10 is the technical heart of EUDR compliance. Three sequential obligations — every DDS must demonstrate all three.
Collect and retain, for 5 years, the eight categories specified in Article 9: product description, quantity, country of production, geolocation (min. 6 decimal places; polygon for plots ≥4 ha), supplier details (previous link in the chain), buyer details (next link in the chain), deforestation-free evidence (Art. 9g), and legality compliance evidence (Art. 9h).
Evaluate the probability of non-compliance — based on country risk tier, prevalence of deforestation in the source region, presence of indigenous peoples, complexity of the supply chain, and quality of the available evidence.
When the risk assessment identifies a non-negligible risk, take mitigation measures: additional information, independent surveys, satellite verification, supplier audits — until risk is reduced to "no or negligible".
04 — Country risk
The Commission classifies producing countries into three tiers — the tier determines how much due diligence is required.
| Tier | Criteria | Compliance impact |
|---|---|---|
| Low risk | Stable forest cover, robust enforcement of local legislation | Simplified due diligence — information collection only |
| Standard risk | Most LATAM countries (Colombia, Peru, Ecuador, Argentina, Uruguay, etc.) | Full Article 10 — information + risk assessment + mitigation if needed |
| High risk | Significant deforestation pressure, weak enforcement (specific Brazilian biomes, parts of Indonesia) | Enhanced due diligence — mandatory mitigation, satellite verification expected |
For most Latin American exporters: standard risk. Article 10 due diligence in full — geolocation, satellite verification against the 31 Dec 2020 baseline, supplier documentation, and risk mitigation if any plot shows post-cutoff forest cover change.
05 — Workflow
The end-to-end compliance workflow — what happens between raw plot data and a EUDR Information System reference number ready for EU customs.
Geolocation of all plots — single point for <4 ha (minimum 6 decimal places), GeoJSON polygon for ≥4 ha; for cattle, establishment-level coordinates. Supplier list with full contact details (Art. 9e/9f). Supporting documents for deforestation-free evidence and legality compliance (Art. 9g/9h).
Country tier lookup, satellite verification of forest cover change vs the 31 Dec 2020 cutoff date, supplier audits if needed.
Structure the Due Diligence Statement following the EU Information System template — commodity, HS code, mass, country, geolocation, supplier, risk assessment, mitigation.
File the DDS in the EU Information System (EUDR Information System). Receive a unique Due Diligence Reference Number. This number accompanies every shipment to EU customs.
Preserve the complete supporting evidence — coordinates, satellite imagery, supplier documentation, audit reports — for at least 5 years from DDS submission, in case of competent authority audit.
EU Information System (EUDR Information System)
The DDS is filed in the official EU system at eudr.webcloud.ec.europa.eu. Each DDS receives a unique reference number. That number, not the DDS itself, accompanies each shipment in customs declarations. The authorized representative model lets a consultant file on behalf of the operator while the legal responsibility remains with the operator.
06 — Article 9 checklist
Article 9 specifies the eight mandatory information categories every DDS must include. All eight must be present — and retained for five years — for a submission to be compliant.
Product description
Trade name and type of the relevant product. For wood products: the common name and full scientific name of each species. Must list all relevant commodities or products contained in or used to make the product.
Quantity
Net mass in kilograms. Where applicable, the supplementary unit per Annex I of Council Regulation (EEC) No 2658/87 (the EU HS nomenclature).
Country of production
The country where the commodity was produced and, where relevant, the specific sub-national region.
Geolocation
For plots <4 ha: a single latitude/longitude point. For plots ≥4 ha: a full GeoJSON polygon. All coordinates must use a minimum of six decimal places. For cattle: geolocation is at the establishment (farm/ranch) level. For all other commodities: at the production plot level.
Supplier (previous link)
Full name, postal address, and email address of every business or person who supplied the relevant products to the operator — that is, the previous link in the chain.
Buyer (next link)
Full name, postal address, and email address of every business, operator, or trader to whom the operator supplied the relevant products — that is, the next link in the chain.
Deforestation-free evidence
Adequately conclusive and verifiable documentation that the products are deforestation-free — typically satellite verification (Sentinel-2, Global Forest Watch) cross-referenced against the 31 Dec 2020 cutoff baseline.
Legality compliance evidence
Adequately conclusive and verifiable documentation that the commodities were produced in accordance with the relevant legislation of the country of production — including land tenure rights, labor law, and indigenous peoples' rights.
Source: Regulation (EU) 2023/1115, Article 9(1)(a)–(h). Operators and non-SME traders must collect and retain all eight categories for a minimum of 5 years from DDS submission.
References
eudr.webcloud.ec.europa.eu10 minutes to find out which obligations apply to your operation, and what it takes to file your DDS before 30 Dec 2026.