3. Architecture of the Regulation — EUDR Guide

3.1 Map of the chapters

Chapter	Articles	Content
1 — General provisions	1 to 3	Subject matter and scope, 40+ definitions, the prohibition
2 — Obligations of operators, downstream operators and traders	4 to 13	Operators' obligations; the simplified regime for MSPOs; downstream obligations; authorised representatives; operators from third countries; due diligence; information requirements; risk assessment and mitigation; the due diligence system and reporting; simplified due diligence
3 — Obligations of Member States and of competent authorities	14 to 25	Competent authorities; technical assistance; checks and annual plans; immediate measures; checks on operators and downstream; cost recovery; cooperation; reporting; interim and corrective measures; penalties
4 — Products entering or leaving the market	26 to 28	Customs controls; cooperation between authorities; the electronic interface (Single Window)
5 — Country benchmarking and cooperation with third countries	29 and 30	Risk classification; partnerships
6 — Substantiated concerns	31 and 32	Third-party complaints; access to justice
7 — Information systems	33	The information system
8 — Review	34	Simplification and general reviews
9 — Final provisions	35 to 38	Delegation; committee; repeal of the EUTR; entry into force and application
Annex I	—	List of relevant commodities and products by CN/HS code
Annex II	—	Content of the due diligence statement
Annex III	—	Content of the simplified statement

3.2 Hierarchy of the sources

Note

How to read the sources together

The Regulation — creates the obligations; it is directly applicable in all 27 Member States, with no need for national legislation (FAQ 1.22).

Delegated and implementing acts — amend Annex I (delegated) and set technical rules such as how the system works and the country list (implementing). Also binding.

The Guidance Document — an interpretation agreed between the Commission and the Member States; it neither replaces nor amends the Regulation, but it guides national authorities and courts.

The FAQ — practical answers from the Commission's services; non-binding, but they indicate how authorities are likely to act.

The infographics — illustrative scenarios of roles and obligations along typical chains.

National rules complete the picture on two points: penalties (Article 25) and the organisation of competent authorities (Article 14).

3.3 The principle of proportionality

The Guidance Document recalls that proportionality is a general principle of Union law and must guide the interpretation and enforcement of the Regulation (Guidance, Introduction; FAQ 10.5). In practice this means that authorities must take the circumstances of each case into account — but the principle does not authorise anyone to ignore express requirements such as geolocation or the cut-off date.

Check what you understood

3 questions on this chapter. Pick an option to see the answer.

1. The Commission Guidance Document is:

It is an interpretation agreed between the Commission and the Member States. It creates no obligation, but it is the reading authorities tend to follow.

2. An importer in Spain claims it will only have to comply with the EUDR once Spain passes its own law. It is:

A regulation applies directly in all 27 Member States (FAQ 1.22). National rules add two things: penalties (Art. 25) and the organisation of competent authorities (Art. 14).

3. A small supplier asks the importer to waive the plot polygons 'on proportionality grounds'. Is that possible?

Proportionality is a general principle of EU law (Guidance Document, Introduction; FAQ 10.5), but it does not erase express requirements such as geolocation or the cut-off date.