27.1 Readiness checklist — exporter
| # | Item | Reference |
|---|
| 1 | Exported products classified and the EUDR scope defined | Annex I; FAQ 2.1 and 2.2 |
| 2 | The role of each European customer identified | Article 2; FAQ 3.1 |
| 3 | Situations in which the company would be an operator mapped | Article 7; FAQ 3.7 |
| 4 | Origination policy with a 31/12/2020 cut-off date approved | Article 2, point 13 |
| 5 | 100% of suppliers with a polygon of the cultivated area per harvest | Article 9(1)(d) |
| 6 | Polygons with six decimal digits, valid, in GeoJSON WGS-84 | Article 2, point 28; FAQ 7.8 |
| 7 | Documented geospatial analysis using the EUDR definition of forest | Guidance, section 11; FAQ 9.10 |
| 8 | Legality file per supplier | Article 9(1)(h); Guidance, section 6 |
| 9 | Indirect suppliers traced | Article 10(2)(i) and (j) |
| 10 | Intake blocked for ineligible areas | Article 3; FAQ 1.5 |
| 11 | Physical segregation or FIFO with the 200% rule in place | FAQ 1.4 and 1.17 |
| 12 | Over-declaration rules defined | FAQ 1.18 |
| 13 | Data pack per lot standardised | Articles 9 to 11 |
| 14 | EUDR and data protection clauses in contracts | FAQ 1.10 and 1.31 |
| 15 | Procedure for notifying the customer of risks | Article 4(5) |
| 16 | Grievance channel and investigation process | Article 31; FAQ 4.15 |
| 17 | Non-compliance and reinstatement protocol | FAQ 1.15 |
| 18 | Evidence retained for at least five years | Article 9(1); Article 12(5) |
| 19 | Teams trained | Article 11(2) |
| 20 | Independent audit and annual review | Articles 11(2) and 12(2) |
27.2 European operator checklist (what the customer must do)
| # | Item | Reference |
|---|
| 1 | Registration in the Information System with an EORI | Article 33; FAQ 7.3 |
| 2 | Documented due diligence system | Article 12 |
| 3 | Collection of all the Article 9 information per product | Article 9 |
| 4 | Documented risk assessment against the 14 criteria | Article 10 |
| 5 | Documented mitigation down to negligible risk | Article 11 |
| 6 | Compliance officer at management level and independent audit (non-SME) | Article 11(2) |
| 7 | DDS submitted before the customs declaration | Article 4(2); FAQ 5.20 |
| 8 | Reference number passed to the first downstream link | Article 4(7) |
| 9 | DDS and evidence retained for five years | Articles 4(3) and 9 |
| 10 | Annual public report (non-SME) | Article 12(3) |
| 11 | Procedure for new information and substantiated concerns | Articles 4(5) and 31 |
| 12 | Annual review of the system | Article 12(2) |
27.3 Minimum data set per lot
| Field | Format | Source |
|---|
| Product and tariff code | Text and code | Product register |
| Quantity | kg of net mass | Invoice / loading list |
| Country and state/municipalities of production | Text | Supplier register |
| Geolocation of the plots | GeoJSON (polygons above 4 ha), 6 decimal digits | Geospatial database |
| Period of production | Harvest year per plot | Harvest register |
| Direct supplier | Name, address, email | Supplier register |
| Result of the deforestation analysis | Report with date, sources and method | Geospatial analysis |
| Result of the legality analysis | File with dated database searches | Socio-environmental analysis |
| Segregation control | Description of the silo regime and reference period | Warehouse |
| Applicable certifications | Standard, number, validity, chain-of-custody model | Certification body |
27.4 Model contract clause (for reference)
27.5 Quick answers
| Question | Short answer | Reference |
|---|
| Does the Brazilian exporter have to submit a DDS? | No, unless it is the importer in the EU (or holds an EORI and places products on the market) | Article 2, point 15; Article 7; FAQ 3.7 |
| Can soy from an area cleared with a permit in 2021 go to the EU? | No, if the area was forest under the EUDR definition | Article 2, points 3 and 13; Guidance, section 11.2 |
| May I declare only the farm closest to the volume shipped? | No; where silos are mixed, declare every intake in the reference period | FAQ 1.17 |
| Is certified mass balance acceptable? | No | FAQ 1.4; Guidance, section 10 |
| Is meal made from 2022/23 soy harvested before 29/06/2023 outside the scope? | Yes, if the date of production before 29/06/2023 is proven | Article 1(2); FAQ 8.3 |
| Is soy protein isolate covered? | No, where classified under 2106 | Infographics, Scenario 4 |
| Is maize covered? | No; it will be assessed in the 2030 general review | Article 34(2)(i) |
| Can one DDS cover a year of shipments? | Yes, subject to the conditions in FAQ 5.19 | FAQ 5.19 |
| Who is fined if the product is non-compliant? | The operator answers for compliance; the other actors answer for their own obligations | Articles 4, 5 and 25 |
| Does the GFC 2020 map decide compliance? | No; it is a non-binding tool | FAQ 9.10 to 9.10.3 |