Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
The EUDR applies to operators, and to downstream operators and traders of any size, from 30 December 2026, about ten weeks from now; only micro and small operators established as such by 31 December 2024, and natural persons, have until 30 June 2027, except for timber products listed in the Annex to the EU Timber Regulation. Setting up your compliance software takes minutes. Collecting plot geolocation, origin and legality evidence from your suppliers takes weeks, because that data sits with people outside your company. Spend the first four weeks on supplier data, assess risk as each supply chain completes, and keep December for resolving flagged risks and test filings. This EUDR checklist sets out the work week by week.
supplier data
The slow part of your EUDR checklist is free. EUDR Passport invites your suppliers, collects plot and origin data and shows per supplier what is still missing.
Why supplier data sets the pace
Every due diligence statement rests on Article 9 information, and most of it comes from your suppliers. For each product and supplier you need:
- the product description, customs (HS) code and quantity
- the country of production
- the geolocation of every plot where the commodity was produced
- evidence that it was produced legally in the country of production
- the supplier’s details, and upstream DDS reference numbers where they exist
None of this is generated inside your business. A trader has to ask a cooperative, the cooperative has to ask its farmers, and someone has to capture coordinates in the field. As a result, each link adds days. Composite products multiply the work: a chocolate bar with cocoa and palm oil needs a data trail for each commodity.
The chain of dependency is strict. No plot data, no risk assessment. No risk assessment, no due diligence statement. And without a DDS reference number, there is no customs clearance. That is why supplier data, not software, decides whether you are ready on 30 December.
Finally, there is one more reason to start now. With typical order-to-delivery lead times of two to four months, goods you order this autumn will be placed on the market after 30 December. They need a DDS reference number even though you ordered them before the deadline. That is why the EUDR checklist below starts with supplier requests in week 1.
The 10-week EUDR checklist
Weeks 1 to 2 (19 Oct to 1 Nov): fix your scope, and send supplier requests anyway
- Run the free EUDR Obligations Checker to confirm your role and your deadline: operator, downstream operator or trader, and whether 30 June 2027 applies to you.
- List your in-scope products by HS code against the amended Annex I, in force since 18 September 2026.
- For each product, list every supplier. One supplier plus one product is one supply chain to assess.
- Send data requests to every supplier in week 1. Do not wait for your scope list to be perfect; you can drop a request later, but you cannot get back lost weeks.
- Register in the EU Information System, or decide to file through an authorised representative.
Weeks 1 to 4 (19 Oct to 15 Nov): run supplier data as a campaign
- Give every supplier one clear request with a due date and the exact format you need.
- Chase non-responders after 7 days, then again after 14.
- In week 3, escalate honestly: orders without data cannot be placed on the market after 30 December.
- Offer help to suppliers who do not know how to capture coordinates. Many smallholders have never been asked.
- Check which suppliers are micro or small primary operators; simplified rules apply to them, so do not over-ask.
- Track completion per supplier, not per product, so you can see who is holding up the most volume.
Weeks 3 to 6 (2 Nov to 29 Nov): assess risk as each supply chain completes
- Do not wait for all suppliers. Assess each supply chain as soon as its data is in.
- Products from low-risk countries can follow simplified due diligence. You still collect the Article 9 information and check supply chain complexity and the risk of mixing.
- Products from standard- or high-risk countries need the full risk assessment under Article 10.
- For cattle, remember that a single coordinate per establishment tells you little about the land around it.
Weeks 5 to 8 (16 Nov to 13 Dec): resolve flagged risks
- For each flagged risk, collect evidence, ask your supplier the follow-up questions and record your reasoning (Article 11).
- Treat certificates as supporting evidence only. FSC and PEFC do not replace your own due diligence.
- Decide what happens to supply chains you cannot clear in time: switch volume to a supplier with complete data, or hold the shipment.
Weeks 7 to 9 (30 Nov to 20 Dec): test the filing and the hand-offs
- File a test due diligence statement and check that the reference number comes back.
- Brief your customs broker: the DDS reference number has to appear on the customs declaration.
- Tell your EU customers how you will pass reference numbers to them.
- Store statements and evidence where you can export them; records must be kept for five years.
Week 10 (21 to 30 Dec): freeze and cover the holidays
- Make a hold list of supply chains without a DDS reference number.
- Name who files statements between Christmas and 30 December, when your team and your suppliers are on leave.
- Check every shipment due to arrive after 30 December against your list of assessed supply chains.
per product
Work through your EUDR checklist and assess risk as each supply chain completes. EUDR Passport runs the risk assessment with 12 months of monitoring and files unlimited due diligence statements to TRACES.
What if a supplier does not deliver in time?
First, prioritise by volume. If three suppliers account for most of your tonnage, get their data first and file for those supply chains. For the rest, you have two honest options: move the volume to a supplier whose data is complete, or keep the goods off the EU market until it is. Placing goods without a valid statement is not an option; the shipment stops at customs before any fine is discussed.
If the dates move again, nothing you collected is wasted. Plot and origin data is the core of every EUDR filing, whatever the final calendar. We explained this in Don’t wait until January 2027: the EUDR deadline trap.
How EUDR Passport helps you finish the checklist in ten weeks
EUDR Passport is built around the slow part. Setting up product profiles, inviting suppliers and collecting their data is free, and suppliers answer in their own free account. You can request a full product profile, one section such as the plots, or a confirmation that nothing changed, each with its own thread and due date. You see per supplier what is in and what is missing.
When a profile is complete, the risk assessment costs €90 per product profile per year, with 12 months of monitoring. From an assessed profile you file as many due diligence statements to TRACES as you need, with no fees per shipment.
Start collecting supplier data today. It is free, and it is the part that takes longest. Book a walkthrough or check your EUDR obligations.
Frequently asked questions
Yes, under current law. Regulation (EU) 2025/2650 sets 30 December 2026 for operators, and for downstream operators and traders of any size, and the Commission's May 2026 review confirmed it. No proposal to change it is on the table.
Only micro and small operators established as such by 31 December 2024, and natural persons, have until 30 June 2027, except for timber products listed in the Annex to the EU Timber Regulation. All other operators, and downstream operators and traders of any size, must comply from 30 December 2026.
Weeks for direct suppliers who hold their data, months for multi-tier chains and smallholder sourcing. Send requests to every supplier now and chase on a fixed schedule.
What counts is when the product is placed on the EU market, not when you ordered it. Goods placed on the market from 30 December need a DDS reference number.
No. Geolocation of the plots of production is part of the information every statement rests on. Micro and small primary operators in low-risk countries follow a simplified regime, but it does not remove the need to identify the land.
30 DECEMBER 2026
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