EUDR Due Diligence Checklist for Importers: What to Request from Your Exporter Before Booking
By Sandra Nansbuga
EUDR Due Diligence Checklist for Importers: What to Request from Your Exporter Before Booking
EUDR green coffee due diligence checklist items should map directly to the information Article 9 of the EU Deforestation Regulation requires an operator to collect: product description, quantity, country of production, plot-level geolocation, supplier details, and verifiable evidence of both deforestation-free status and legal production. There is no single official EU checklist template, since the European Commission's own guidance states due diligence is not a fixed tick-box process, but Article 9's requirements translate into seven practical items a buyer can request from an exporter before confirming an FOB or CIF order.
What EU due diligence actually requires
Under the European Commission's Green Forum guidance on the EUDR, operators must complete a three-step process before placing a relevant product on the EU market or exporting it: collecting the information listed in Article 9, assessing risk under Article 10, and mitigating any non-negligible risk under Article 11. Article 9 specifically requires a product description, the quantity expressed in net mass, the country of production, the geolocation of every plot of land where the commodity was produced along with the date or time range of production, the identity of suppliers, and adequately conclusive and verifiable evidence that the product is both deforestation-free and legally produced. The regulation applies from 30 December 2026, and any deforestation or forest degradation on a given plot after 31 December 2020 automatically disqualifies commodities from that plot.
The seven-point checklist
1. Product description matching the regulation's product scope. Confirm the exporter can provide a description, including trade name and type, that corresponds to the commodity and HS code categories the EUDR covers.
2. Quantity in net mass. Request the shipment quantity expressed in kilograms of net mass, matching the format Article 9 requires for the due diligence statement.
3. Country and region of production. Confirm the exporter can specify not just Uganda as the country of production but the relevant growing region or regions within it, since geolocation data is tied to specific plots, not the country as a whole.
4. Plot-level geolocation data, in the correct technical format. Request geolocation coordinates for every plot supplying the lot, along with the production date or time range. This data must ultimately be submitted to the EU's Information System in GeoJSON format using the WGS84 coordinate system, so confirming the exporter's data is already structured this way, or can be converted to it, avoids a late-stage compliance bottleneck.
5. Supplier chain documentation. Request the names and contact details the exporter holds for its own upstream suppliers, since this traceability chain is part of what Article 9 requires an operator to collect and retain.
6. Deforestation-free evidence tied to the 31 December 2020 cutoff. Ask specifically how the exporter verifies that supplying plots were not deforested or degraded after that date, since this is the operative cutoff under the regulation.
7. Legality evidence for the country of production. Request documentation showing the commodity was produced in accordance with Uganda's relevant laws, including any land-use rights or licensing tied to the specific plots.
What this means for buyers
A checklist only works if it's verified, not just collected. Article 9 requires the information to be adequately conclusive and verifiable, not merely supplied. Buyers should ask how each item was verified, not just whether the exporter can produce a document, since a due diligence statement built on unverifiable claims does not satisfy the regulation.
Geolocation data format is a common late-stage failure point. Because the EU's Information System accepts geolocation submissions only in a specific technical format, buyers should confirm this earlier in the relationship rather than discovering a formatting gap close to a booking deadline.
A single due diligence statement can cover multiple shipments, which affects how you structure repeat orders. Since one DDS can apply to multiple batches placed on the market over time, buyers placing recurring orders with the same exporter and supply base may be able to negotiate coverage under a single statement rather than requiring a fresh one for every shipment, reducing administrative overhead on both sides.
This checklist supports due diligence; it does not replace it. Collecting these seven items from an exporter is the information-gathering step only. Buyers who are non-SME operators or traders under the regulation still carry their own risk-assessment and, where relevant, verification obligations, and should not treat a completed exporter checklist as a substitute for their own compliance process.
FAQ
Is there an official EU checklist for EUDR due diligence?
No. The European Commission's own guidance states there is no fixed checklist format, since the due diligence approach can vary by supply chain, the seven items above are derived directly from the information Article 9 requires operators to collect.
What is the deforestation cutoff date under the EUDR?
Commodities produced on land subject to deforestation or forest degradation after 31 December 2020 are automatically disqualified from being placed on the EU market or exported.
When does the EUDR apply?
The regulation applies from 30 December 2026, according to the European Commission's own implementation guidance.