24. The Brazilian soy chain under the EUDR — EUDR Guide

24.1 Who is who in a typical shipment

Link	Example	EUDR role	Direct legal obligations
Farmer in Brazil	Supplying farm	None (does not place products on the EU market)	None under the EUDR — but contractual obligations to provide data and warranties
Brazilian originator, warehouse operator, crusher and exporter	A company that buys, stores, processes and ships	None in conventional FOB/CIF sales; an operator where it is the importer in the EU and holds an EORI	None in conventional sales; in DDP sales or where it imports on its own account, all the operator's obligations
European importer (whoever declares release for free circulation)	A trader, crusher or feed manufacturer in the EU	Operator	Full due diligence, a DDS before the customs declaration, responsibility for compliance, an annual report if a non-SME
First buyer in the EU from an importer established outside the EU	A distributor in the EU	Operator (Article 7)	The same
EU crusher buying already declared beans	European crusher	First downstream operator	Registration (if a non-SME), keeping reference numbers and partner data for 5 years, the duty to inform
Feed manufacturer buying meal from the importer	Feed mill	First downstream operator where the meal is resold as such; no obligations where it is turned into compound feed outside Annex I	As the case may be
EU cattle farmer using the meal	Cattle producer	Must ensure the feed is not associated with deforestation, where placing cattle on the market	Documentation on the feed (recital 39; FAQ 1.26.1)

24.2 What the European customer will ask for

For the importer to comply with Articles 9 to 11, the Brazilian exporter will have to deliver, per contract, lot or period:

Description and classification — product, tariff code, quantity in kg of net mass.
Country and parts of the country of production — states and municipalities of origin.
Geolocation — polygons (for areas above 4 ha) of every plot that supplied the lot, or of every plot that delivered into the silos and plants during the reference period, in GeoJSON WGS-84 with six decimal digits.
Date or period of production — harvest year per plot.
Evidence of the absence of deforestation — geospatial analysis of each plot against 31/12/2020, with sources, dates and method.
Evidence of legality — a socio-environmental file per supplier (CAR, embargoes, overlaps, slave-labour register, land use rights).
Assurance of segregation — a description of the control system at intake, storage, processing and shipment that prevents mixing with unknown origin.
Direct supplier data — name, address and email.
Information for the risk assessment — complexity of the chain (direct and indirect suppliers), history of non-compliance, certifications and audits.
A commitment to communicate — immediate notice of new risk information and support in the event of a check or a substantiated concern.

24.3 Risks specific to the Brazilian chain

Risk	Description	Article 10(2) criterion	Suggested mitigation
Standard country classification	Brazil is not on the low-risk list	(a)	A complete data pack; demonstration of controls by region
Conversion in the Cerrado	Lawful clearing of vegetation that falls within the FAO concept of forest, after 2020	(b), (f)	Geospatial analysis using national and European maps; blocking plots converted after 31/12/2020
Quality of the CAR	A self-declared registry, with a low rate of review by the agencies and risks of overlap and of boundary changes	(g), (h)	Cross-checking against SIGEF, imagery and site visits; version history of the polygon
Indirect suppliers	Beans bought from grain merchants, cooperatives or producers who aggregate third-party volumes	(i), (j)	Registration and geolocation of indirect suppliers; a contractual requirement of upstream traceability
Grain "laundering"	Production from a non-compliant area sold in the name of a compliant one	(j)	Yield checks by area and harvest; invoices; volume consistency
Mixing in warehouses	Joint intake of grain from compliant and unknown origins	(j)	Eligibility screening before intake; physical segregation; the 200% rule under FIFO
Indigenous lands and traditional communities	Overlap or conflict	(c), (d), (e)	Cross-checking against FUNAI, INCRA and state databases; conflict analysis
Labour analogous to slavery	Presence on the Ministry of Labour register or citations	(l), (m)	Periodic checks; blocking and a reinstatement protocol
Environmental embargoes	Active IBAMA or state embargoes	(b), (m)	Checks by taxpayer number and by polygon
Corruption and document fraud	Forged or irregularly issued documents	(h)	Verification against official databases rather than copies; independent auditing
Personal data	Polygons and producers' taxpayer numbers are personal data under Brazil's data protection law (LGPD)	—	A legal basis and contractual clauses for sharing; data minimisation

24.4 The life cycle of an exported lot

Figure 5 — From the field to the European port

Stage	EUDR control	Evidence generated
1. Supplier registration	Identification, CAR, polygons of the soy areas, land use documents	Supplier record and validated polygons
2. Eligibility analysis per harvest	Post-2020 deforestation, embargoes, overlaps, slave-labour register, legality	Dated eligibility report
3. Purchase contract	Clauses on traceability, origin, accuracy and data sharing	Signed contract
4. Intake	Automatic blocking of an ineligible supplier or area; linking the invoice to the plot	Georeferenced intake record
5. Storage	Dedicated silos or controlled FIFO; a record of intake by period	Silo log; the 200% calculation
6. Processing	Control of inputs into continuous crushing	Input balance by period
7. Dispatch and shipment	Linking the lot to the declarable origins; segregation at the port	Shipment file
8. Data pack to the customer	GeoJSON, reports, legality declaration, description of the system	The lot's EUDR pack
9. DDS by the importer	Use of the data in risk assessment and mitigation	DDS reference number
10. After the sale	Monitoring of new information and substantiated concerns, 5-year retention	Incident log