What the EU Deforestation Regulation actually requires: the legal framework, the workflow, and the technical evidence the EU Information System expects from operators, downstream 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 and medium-sized operators, downstream operators and all traders, and 30 June 2027 only for micro and small operators established as such on 31 December 2024.
Authorized representative
Article 6 of the regulation allows operators to appoint an authorized representative to submit the DDS on their behalf.
Dexffo acts as authorized representative for operators placing products of Latin American origin on the EU market: collecting evidence along the supply chain, structuring the DDS, filing it in the EUDR Information System, and delivering the reference number to the operator.
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 an operator if you place relevant products on the EU market for the first time, or export them from the EU. Usually this is the EU importer (Art. 2(15)). A Latin American exporter that sells to an EU importer is not the operator for that sale. It is one only if it places the product on the EU market itself.
Trader or downstream operator
You buy and re-sell, or process, products already placed on the EU market by an operator earlier in the chain. You do not file a DDS: you register (if non-SME) and keep traceability records.
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 screening, 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 screening expected |
Most Latin American countries of production are standard risk. Chile, Costa Rica and Uruguay are low risk (Implementing Regulation 2025/1093). At standard risk, the operator applies Article 10 due diligence in full: geolocation, satellite screening 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 screening 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, downstream 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 screening (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), as amended by Regulation (EU) 2025/2650. Operators must collect and retain all eight categories for a minimum of 5 years from placing on the market or export (Art. 9(1)), and keep a record of each DDS for 5 years from its submission (Art. 4(3)). Traders and downstream operators have their own obligations (Art. 5).
07: FAQ
Regulation (EU) 2023/1115 prohibits placing products linked to deforestation on the EU market after 31 December 2020. It covers seven commodities: cattle, cocoa, coffee, oil palm, soy, timber, and rubber. Every shipment must be accompanied by a Due Diligence Statement (DDS) filed in the EU Information System (EUDR Information System).
The EUDR covers seven commodities and their derived products: cattle, cocoa, coffee, oil palm (palm oil), soy, timber, and rubber. Products derived from these commodities (such as coffee extracts, chocolate, soy flour, or paper) are also covered.
Large and medium-sized operators, downstream operators and all traders (of any size) must comply by 30 December 2026. Only micro and small operators (including natural persons) established as such on 31 December 2024 have until 30 June 2027 (Art. 38 of Reg. (EU) 2023/1115, as amended by Reg. (EU) 2025/2650). The deforestation cutoff date is 31 December 2020; production must have occurred on land that was not deforested after that date.
A Due Diligence Statement is a formal declaration filed in the EU Information System (EUDR Information System) that demonstrates a shipment of covered commodities is deforestation-free and legally produced. It must include geolocation data, supplier information, satellite screening evidence, and a risk assessment. A unique DDS reference number accompanies each shipment through EU customs.
EUDR Information System (eudr.webcloud.ec.europa.eu) is the EU Information System where Due Diligence Statements are filed. It is operated by the European Commission and generates a unique Due Diligence Reference Number for each submission. That reference number is required for all EU customs declarations for covered commodities.
Article 6 of Regulation (EU) 2023/1115 lets an operator mandate an authorized representative established in the EU to submit the Due Diligence Statement on its behalf. The operator remains responsible for compliance. Dexffo acts as authorized representative for operators placing coffee, cocoa, timber, soy and cattle of Latin American origin on the EU market, and works with the supply chain that provides the origin data.
Article 25 requires Member States to provide for fines whose maximum, for a legal person, is at least 4% of annual EU turnover, as well as confiscation of the products and of the revenues from them, temporary exclusion from public procurement and public funding and, for serious or repeated infringements, a temporary ban on placing covered products on the EU market. The rules apply from 30 December 2026; only operators that are natural persons or micro or small undertakings established as such by 31 December 2024 have until 30 June 2027, except for timber products covered by the former EU Timber Regulation.
It depends on who places the product on the EU market. The obligations fall on the operator: whoever places it on the EU market for the first time, usually the EU importer (Art. 2(15)). An exporter outside the EU that sells to an EU importer has no direct obligations under the Regulation, but its buyer will ask it for the geolocation of the plots and evidence of origin. If the exporter places the product on the EU market itself, it is the operator and can mandate an EU-established authorized representative under Article 6 to submit the DDS.
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.