Your EU customer files the EUDR statement. The evidence starts with you.

The EU Deforestation Regulation applies from 30 December 2026. Since the December 2025 revision, the duty to file the due diligence statement sits only with the business that first places the product on the EU market. Businesses further down the chain no longer file their own.

For most exporters in the UK, the US and Asia, that first business is their EU customer. The customer signs the statement. But almost everything the statement relies on has to come from the supplier. Expect the questions before December, not after.

Who files, after the December 2025 changes

• The first operator in the EU files the due diligence statement and carries the due diligence.
• The first downstream buyer collects and keeps that statement’s reference number. It does not have to pass it further down.
• Other downstream businesses and traders no longer file statements. Large ones must still register in the EU information system.

The change cut the number of statements. It did not cut the evidence. The first operator still needs it, and in most chains it can only get it from the supplier.

A low-risk country is not a low-evidence country

In May 2025 the Commission classified 140 countries as low risk, including the UK, the US, China and all EU member states. Belarus, Myanmar, North Korea and Russia are high risk. Every other country is standard risk.

Low risk allows simplified due diligence: the operator can skip the formal risk assessment and mitigation steps. It still has to collect the full set of information, geolocation included. Authorities also check a share of operators every year: 1% for low-risk origins, 3% for standard and 9% for high.

The classification follows the country where the commodity was produced, not where it was shipped from. A US chocolate maker or a UK furniture exporter is judged on where its cocoa or timber grew. For much of the world’s cocoa, coffee, palm oil and rubber, that is a standard-risk country.

What your customer will ask for

The questions follow the information the regulation requires. In practice they come down to four groups:

1. The product: description, customs code and quantity.
2. Where it was produced: country, the geolocation of every plot of land, and the date or period of production.
3. Who it passed through: each supplier’s name and address, and any statement reference already attached to the goods.
4. Proof: that the land was not deforested after 31 December 2020, and that production met the laws of the country where it took place.

We have set out the full list as a one-page checklist at the end of this note.

Where the requests stall

• Geolocation stops at the first aggregator. Cooperatives, collectors and mills mix lots before an exporter sees them. Without plot data from that first link, the chain cannot be completed.
• Certificates are treated as answers. A sustainability certificate can support a file. It does not supply plot coordinates or prove the legality of a specific lot.
• Legality is assumed, not shown. Land rights, labour and tax compliance in the producing country need documents, often in the local language.
• Mixed stock breaks the link. Once traced and untraced material share a silo or warehouse, the traced material loses its proof.

Already had a request from an EU customer? Tell us what you supply, and we will reply within one working day with where the gaps are likely to sit. Start here →

Where we come in

Meridian Intermediaries builds the evidence behind a supplier’s answer. We identify who produced the goods, where and on what land, and what documents prove it. We grade each link by how well it is evidenced. Where a link cannot be verified, we say so plainly, so you and your customer decide with the facts in front of you.

What to do this month

• Ask your EU customers what they will need from you, in what format, and by when.
• Map each product to the country where its commodity was produced, not where you bought it.
• Test one shipment end to end: can you produce plot data and legality documents for it today?
• Decide now what happens to orders after 30 December where the evidence is incomplete.

Read our earlier note on the 30 December application date and product scope.