EUDR Compliance Ops Checklist

🔒Unlock 10 practical steps, in the right order, to fully prepare for EUDR by 30 Dec 2026—don’t risk being caught off guard!

Even with a potential delay, customs professionals must prepare for enforcement. The EUDR requires that importers demonstrate deforestation-free sourcing for commodities including:

• Palm oil

• Soy

• Cocoa

• Coffee

• Timber

• Beef

• Rubber

Derivatives are also included. Non-compliance can result in shipments being blocked at the border, causing operational, legal, and reputational consequences.

Key Compliance Requirements

Customs officers should be aware that importers must conduct robust due diligence:

1. Traceability: Identify the origin of goods and all suppliers.

2. Risk Assessment: Evaluate deforestation or land degradation risks.

3. Mitigation: Document measures to reduce identified risks.

4. Geolocation: Provide precise land coordinates, verified via satellite imagery or on-site checks.

Importers must submit a formal due diligence declaration to EU authorities prior to clearance. Customs may request these records during inspections, audits, or routine enforcement.

EUDR Operational Checklist for Customs Professionals

1. Verify Importer Registration

• Confirm the importer is registered as an economic operator in the EUDR system.

• Note potential delays if the IT system is not fully operational.

• Flag incomplete registrations for follow-up once the system is fully functional.

2. Commodity Scope Verification

• Confirm the shipment falls under EUDR coverage:

  • Palm oil, soy, cocoa, coffee, timber, beef, rubber.

  • Derivatives of the above commodities.

• Flag mixed or processed products for additional checks.

  
  

3. Identify Your Role in the Supply Chain

• Determine whether you are an operator, a trader, or another actor.

• Understand that upstream operators carry heavier compliance obligations; downstream traders have lighter duties.

  
  

4. Assess Company Size

• Large or complex operators face more requirements than SMEs or micro-enterprises.

  
  

5. Evaluate Country Risk

• Consider the deforestation or land degradation risk of the countries from which you import EUDR-relevant products.

• Flag high-risk origins for closer scrutiny.

  
  

6. Due Diligence Statement Submission

• Confirm that a formal due diligence statement is submitted for each applicable shipment.

• Ensure it includes:

  • Commodity identification (type and derivatives)

  • Supplier and origin details

  • Risk assessment of deforestation or land degradation

  • Mitigation measures taken

  • Geolocation data (coordinates of origin)

• Allow for potential delays in IT confirmation for small or multiple-package shipments.

  
  

7. IT System Considerations

• Anticipate potential slowdowns or outages in the EUDR IT system.

• Document cases where system issues prevent timely registration, submission, or verification.

• Maintain manual records if IT submission fails.

• Coordinate with authorities for guidance on temporary procedures.

  
  

8. Risk Assessment & Enforcement

• Identify shipments from high-risk origins (e.g., Indonesia for palm oil).

• Flag shipments with incomplete or suspicious due diligence for follow-up.

• Track compliance during potential delays; enforcement resumes fully once the IT system is ready.

  
  

9. Traceability & Geolocation Checks

• Ensure geolocation data is provided and verifiable (satellite or on-site).

• Confirm the chain of custody from origin to EU entry.

• If IT system access is limited, request supporting documentation directly from the importer.

  
  

10. Coordination & Reporting

• Liaise with national Competent Authorities for guidance on IT-related delays.

• Report operational issues caused by system limitations.

• Maintain clear communication with importers regarding submission deadlines and system readiness.

  
  

Takeaways

• The proposed delay provides extra preparation time but does not change compliance requirements.

• The EUDR delay does not remove compliance obligations. Customs officers must be ready to enforce once the IT system and regulation are fully operational.

• Customs professionals must remain ready to enforce the EUDR once active, particularly for high-risk imports like palm oil from Indonesia.

• The delay is driven primarily by IT system readiness, not regulatory intent—ensuring authorities can process due diligence declarations without disruption.