17.1 Who enforces
Each Member State designates one or more competent authorities with the powers, functional independence and resources to apply the Regulation (Article 14). The Commission publishes and updates the list. In the version of 19/01/2026, some countries still had no authority listed (Greece, Malta and Poland appeared without data). The arrangements vary: some countries have one authority for wood and another for agri-food commodities (Bulgaria, Italy, Latvia, Lithuania, Portugal, Romania); others have a single agency (Germany — BLE; the Netherlands — NVWA; Belgium — the Federal Environmental Inspectorate). The full list is in Annex D.
17.2 Technical assistance (Article 15)
Member States and the Commission may provide technical assistance and guidance, taking the situation of SMEs into account, including help with converting data into geolocation. Such assistance does not compromise the independence of the authorities and does not transfer responsibility away from operators. The Commission may facilitate harmonised application through guidance, exchanges with experts and the multi-stakeholder platform on forest protection and restoration.
17.3 Annual plans and the risk-based approach (Article 16)
The authorities check whether operators, downstream operators and traders established in the EU comply with the Regulation and whether the products are compliant. Checks are risk-based, taking into account: the commodity; the complexity and length of the chain, including any mixing of products; the stage of processing; the proximity of the plots to forests; the country risk classification; a history of non-compliance; the risk of circumvention; and other information, such as monitoring data, profiles from international organisations, substantiated concerns and the conclusions of expert groups.
Each authority draws up annual plans with national risk criteria (which incorporate indicative EU criteria and always include criteria for high-risk countries) and with the selection of companies and, where applicable, of specific DDS to be checked, using electronic data processing techniques. The plans are reviewed annually in the light of the results and shared with the other authorities and the Commission.
17.4 Minimum check targets
| Classification of the country of production | Annual minimum of checks | Legal basis |
|---|---|---|
| Low risk | 1% of operators, non-SME downstream operators and non-SME traders | Article 16(10) |
| Standard risk (Brazil) | 3% of operators, non-SME downstream operators and non-SME traders | Article 16(8) |
| High risk | 9% of operators, non-SME downstream operators and non-SME traders and 9% of the quantity of each product | Article 16(9) |
- The targets are met separately for each commodity, calculated on the number of actors in the previous year and, where relevant, on the quantity (Article 16(11)).
- An operator counts as checked once the authority has examined its due diligence system and documentation for specific products (Article 18(1)(a) and (b)); downstream, once it has examined the Article 5 documents (Article 19(1)).
- Beyond the planned checks, the authority acts whenever it receives relevant information, including a substantiated concern (Article 16(12)).
- Checks are carried out without prior notice, except where notice is necessary for them to be effective (Article 16(13)).
- Records of checks are kept for at least 10 years and constitute environmental information accessible to the public on request (Article 16(14) and (15)).
17.5 What is checked
Operators (Article 18). Mandatory: examination of the due diligence system — risk assessment and mitigation included — and of the documentation showing that it works; examination of the compliance documentation for specific products and of the DDS (or simplified statements). Where there is doubt, checks may also include:
- physical examination of the products against the documentation;
- examination of the corrective measures taken;
- technical and scientific means to determine the species or the exact place of production, including anatomical, chemical or DNA analysis;
- technical and scientific means to determine the absence of deforestation, including Copernicus Earth observation data and other public and private sources;
- spot checks and field audits, including in third countries with their agreement and in cooperation with their authorities.
Downstream operators and traders (Article 19). Examination of the documentation under Article 5(1) to (4) and, where there is doubt, on-site checks and audits.
17.6 Immediate measures and suspensions (Article 17)
Where authorities identify products with such a high risk of non-compliance that action is needed before they are placed on the market, they record the situation in the Information System. When a DDS concerning those products is submitted, the system flags the high risk and the authority adopts an interim suspension measure (or, once the customs interface is operating, asks customs to suspend release).
The suspension ends after three working days — or 72 hours for perishable products — but may be extended by further periods of three working days where the authority needs more time (Article 17(3); FAQ 9.11).
17.7 Costs, cooperation and reporting
- Cost recovery (Article 20): Member States may allow companies to be charged the costs of activities relating to cases of non-compliance — testing, storage and corrective measures.
- Cooperation (Article 21): authorities cooperate with one another, with customs, with the Commission and, where necessary, with third-country authorities; they alert the others when they detect non-compliance that may affect more than one Member State, so that withdrawal or recall can be organised across the EU.
- Reporting (Article 22): by 30 April each year, Member States publish information for the previous year — plans and risk criteria, the number and results of checks, quantities checked, countries of production, corrective measures, penalties and the percentage of checks carried out with prior notice. By 30 October, the Commission publishes an EU-wide summary. The first full cycle of data covers 2027.
