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EUDR

EUDR Supplier Maturity Assessment - Detailed

To assess whether suppliers are compliant with the EU Deforestation Regulation (EUDR), they are required to complete a Supplier Maturity Assessment. This assessment gathers important information regarding their readiness to meet the legal obligations

The Supplier Maturity Assessment covers several key areas as:

Responsibility and readiness of the Due Diligence System (DDS)
Compliance and legislation
Risk assessment
Risk Mitigation matters

If the Supplier Maturity Assessment results are positive and a Due Diligence Statement (DDS) has been provided in advance, the supplier will be authorized to continue placing goods at the EU market. However, if the assessment reveals that the supplier is not ready or lacks necessary compliance measures, they will need to take the required steps before they can import/export relevant products within or from the EU. In short, without a positive Supplier Maturity Assessment and the appropriate DDS, the process cannot proceed.

A supplier maturity assessment includes key questions that help identify potential risks and will be highlighted with a red flag icon 🚩 within this article. If any one of these red flag questions is answered negatively, the entire assessment will be considered critical. In that case, you’ll need to go through the full due diligence process, which involves performing deforestation checks and a legality assessment.

Responsibility and readiness

In the first section of the questionnaire, the focus is on understanding the responsibility and readiness of the supplier's Due Diligence System. We will ask who is accountable for its implementation within the organization and whether a Due Diligence system has already been put in place. The answers (such as "Yes, implemented", "No, partially implemented" or "No, not implemented") will determine which additional questions follow.

Who is responsible for EUDR implementation within your organisation? * (Full Name / Email Address / Job Title)

The operator or trader responsible for placing or making a relevant product available on the EU market, or for exporting it, is accountable for the product's compliance and overall adherence to the Regulation. It is important to designate a person to oversee EUDR implementation and compliance. Therefore, it is essential to request the contact information to ensure clear accountability.

Do you have an EUDR Due Diligence System in place? * (Yes / No, partially implemented / No, not implemented) 🚩

and will therefore be able to provide Due Diligence Statements by December 30th 2025?

> Yes

Will you be able to provide a Due Diligence Statement (DDS) for all your EUDR-relevant products by December 30th 2025

If Yes → main question set

If No, user is asked to specify (open question): The share of your EUDR-relevant products covered by a Due Diligence Statement (DDS) by December 30th 2025

The reason why not all EUDR-relevant products are covered by a Due Diligence Statement (DDS) by December 30th 2025

> No, partially implemented / No, not implemented

Will your EUDR Due Diligence System be ready by December 30th 2025?

If Yes → The share of your EUDR-relevant products covered by a Due Diligence Statement (DDS) by December 30th 2025

The reason why not all EUDR-relevant products are covered by a Due Diligence Statement (DDS) by December 30th 2025

If No → Will your EUDR Due Diligence System be ready after December 30th 2025?

If Yes, user is asked to provide a date

If No, user is sent to the following question:

Please let us know why:

None of our products are EUDR-relevant
Outside of the EU
We are waiting to see when the law becomes applicable
Other (please describe)

In order to ensure that the relevant products that they intend to place on the market comply with the deforestation-free and legality requirements of this Regulation, a Due Diligence System has to be established and implemented and the operator has to be able to provide Due Diligence Statements.

Will you be able to provide a Due Diligence Statement (DDS) for all your EUDR-relevant products by December 30th 2025 * (Yes / No) 🚩

In order to be EUDR compliant and place certain products on the EU market, the operator has to be able to provide Due Diligence Statements.

As part of your EUDR Due Diligence System, do you collect information, documents and data as required by Article 9 EUDR which demonstrate that the relevant products are (i) deforestation-free and (ii) have been produced in accordance with the relevant legislation of the country of production? * (Yes / No) 🚩

Operators are required to provide specific information to demonstrate their compliance with the EUDR. The details they must collect are outlined in the next section of the questionnaire, as specified in Article 9, Paragraph 1. All of these requirements must be met in order to create a Due Diligence statement and for relevant products to be placed on the EU market.

Information Requirements

Operators shall collect information, documents and data which demonstrate that the relevant products comply with Article 3. For this purpose, the operator shall collect, organise and keep for five years from the date of the placing on the market or of the export of the relevant products the following information, accompanied by evidence, relating to each relevant product.

1.As part of your EUDR Due Diligence System, do you collect information, documents and data as required by Article 9 EUDR which demonstrate that the relevant products are (i) deforestation-free and (ii) have been produced in accordance with the relevant legislation of the country of production?

Operators are required to provide specific information to demonstrate their compliance with the EUDR. The details they must collect are outlined in the next section of the questionnaire, as specified in Article 9, Paragraph 1. All of these requirements must be met in order to create a Due Diligence statement and for relevant products to be placed on the EU market.

Which of the information mentioned in Article 9 Para. 1 do you collect?

2. A description of the products * (Yes / No) 🚩

A description of products is a mandatory information to create Due Diligence Statements. The product description shall include the list of relevant commodities or relevant products contained therein or used to make those products. In the case of relevant products that contain or have been made using wood, the common name of the species and their full scientific name has to be included. Otherwise a description with the trade name and the type of the relevant product is enough.

3. The quantity of the relevant products * (Yes / No) 🚩

Another information requirement for a DD statement creation is the quantity of the relevant products. For relevant products entering or leaving the market, the quantity is to be expressed in kilograms of net mass and also the indicated Harmonised System code (HS) needs to be included.

4. The country / countries of production * (Yes / No) 🚩

The country of production is required because the risk associated with a product varies depending on its origin, as outlined by the EU benchmark. This information is necessary to verify whether the relevant product has been sourced from a deforestation-free area.

5. The geolocation of all plots of land where the commodities were produced * (Yes / No) 🚩

This is in relation to the relevant products that contain or were manufactured with the aforementioned commodities

To conduct deforestation checks and verify that the product complies with the EUDR, it is essential to provide the geolocation data for all plots of land where the relevant commodities used in the product were grown or produced. For cattle, this includes every location where the animals were raised. By providing this geolocation information, we can cross-check it with our partner, Satelligence, to ensure that the commodities meet the regulatory requirements.

6. The date or time ranges of production * (Yes / No) 🚩

To verify whether relevant products contain, have been fed with, or have been made using commodities produced on land that has not been subject to deforestation after 31 December 2020, it is necessary to specify the date or time range of production.

7. The name, postal address and email addresses of any business or person from whom you have been supplied with the relevant products * (Yes / No) 🚩

This data is essential not only for conducting deforestation checks but also for legality assessments, as a legality review must be carried out for each producer to assess their risk score. The legality assessment relies on this risk score, and targets must be validated in order to generate alerts and receive an alert score.

8. The name, postal address and email addresses of any business, operator or trader to whom you have supplied the relevant products * (Yes / No) 🚩

It is essential to know the business, operator, or trader to whom you supply products, as this information is required to generate a Due Diligence statement, which is also mandatory for exporting products.

9. Adequately conclusive and verifiable information that the relevant products are deforestation-free * (Yes / No) 🚩

To demonstrate that products placed on the EU market are deforestation-free, verified information must be provided. This includes geolocation data (origin information), which must be included in the Due Diligence Statement and the legality assessment.

10. Adequately conclusive and verifiable information that the relevant commodities have been produced in accordance with the relevant legislation of the country of production * (Yes / No) 🚩

It means that information has to be provided for laws applicable in the country of production concerning the legal status of the area of production in terms of: (a) land use rights; (b) environmental protection; (c) forest-related rules, including forest management and biodiversity conservation, where directly related to wood harvesting; (d) third parties’ rights; (e) labour rights; (f) human rights protected under international law; (g) the principle of free, prior and informed consent (FPIC), including as set out in the UN Declaration on the Rights of Indigenous Peoples; (h) tax, anti-corruption, trade and customs regulations.

11. To the extent you do not collect information on questions 2 to 10 above, please explain why

Operators are required to gather the necessary information, documents, and data that demonstrate the compliance of relevant products. This includes collecting, organizing, and retaining the required information, as outlined in questions 2-10, along with supporting evidence, for a period of 5 years from the date the product is placed on the market or exported. Failure to meet this requirement may result in the products not being considered EUDR compliant. For clarity, operators should also provide an explanation if, for any reason, they are unable to collect the required information.

12. As part of your EUDR Due Diligence System, do you verify that the relevant products are deforestation-free? * (Yes / No) 🚩

On the basis of a systemic approach, operators should take the appropriate steps in order to ensure that the relevant products that they intend to place on the market comply with the deforestation-free and legality requirements of this Regulation. Therefore you need to collect information, data and documents to fulfill the requirements set out in Article 9, risk assessment measures as referred to in Article 10 and risk mitigation measures as referred to in Article 11.

13. What is your source of information to verify that the relevant products are deforestation-free? * (Yes / No)

Please provide name(s) of satellite data provider(s). e.g. Satelligence, Global Forest Watch, Descartes, Carto, EU Forest Observatory, Other

Satellite data providers should be used to conduct a deforestation assessment, verifying whether relevant products contain, have been fed with, or have been made using commodities produced on land that has been subject to deforestation after 31 December 2020.

14. Does your (or your service/data provider's) analysis adhere to the EUDR's definition of 'deforestation-free' according to Article 2 Para. 13? * (Yes / No)

Remotely sensed data (such as aerial photographs or satellite images) or other sources of information (e.g., field photographs with geotags and timestamps) may be used to verify the geolocation of declared commodities and assess their link to deforestation. Operators are required to determine whether relevant products contain, have been fed with, or have been made using commodities produced on land that has not experienced deforestation after 31 December 2020. For products containing or made with wood, it must also be confirmed that the wood was harvested without causing forest degradation after this date. If a deforestation check reveals non-compliance, the product must not be placed on the EU market.

15. Do you use a different approach?

please explain the different approach

Legislation consideration

To strengthen the Union’s contribution to halting deforestation and forest degradation, and to ensure that relevant products from supply chains related to deforestation and forest degradation are not placed on the market or exported, relevant products should not be placed or made available on the market or exported unless they are deforestation-free and have been produced in accordance with the relevant legislation of the country of production. Relevant legislation may include, among others, national laws (including relevant secondary law) and international law as applicable in domestic law. The Regulation provides a list of legislative areas without specifying particular legal acts, as these differ from country to country and may be subject to amendments. According to the definition, the legislation listed must be interpreted as being concerned with the legal status of the area of production. Additionally, for the different fields of legislation, the meaning and purpose stipulated in Art. 1(1)(a) and (b) EUDR should be taken into account. Therefore, among others, legislation with a link to the protection of forests, the reduction of greenhouse gas emissions or the protection of biodiversity is relevant.

Which legislation do you take into consideration when assessing compliance with relevant legislation of the countries of production?

16. Land use rights * (Yes / No) 🚩

The Regulation requires compliance with relevant national laws. If farmers are legally allowed to sell their product under national laws (which might lack a property register and where some farmers might lack IDs), then that would also mean that operators (or traders that are not SMEs) would meet the legality requirement when sourcing from those farmers. If possession of a land title is not required under domestic law to produce and commercialize agricultural products, then it is not required under the Regulation. Operators (or traders that are not SMEs), nonetheless, would need to verify that there is no risk of illegality in their supply chains.

17. Environmental protection * (Yes / No) 🚩

According to the legislation, a link to the protection of forests, the reduction of greenhouse gas emissions or the protection of biodiversity is relevant. Therefore it is important to take environmental protection into account and you need to check if it complies with the relevant legislation of the countries of production.

18. Forest-related rules, including forest management and biodiversity conservation, where directly related to wood harvesting * (Yes / No) 🚩

Deforestation under the Regulation is defined as conversion of forest to agricultural use. Conversion for other uses such as urban development or infrastructure does not fall under the deforestation definition. For instance, wood from a forest area that has been legally harvested to build a road would be compliant with the Regulation. Forest management and biodiversity conservation, where directly related to wood harvesting, have to be considered.

19. Third parties' rights * (Yes / No) 🚩

Third Party Rights refer to the rights and benefits that a contract grants to a party who is not directly involved in the agreement. There are instances when the parties agree to confer a benefit or obligation towards a third party, who becomes entitled to enforce certain terms of the contract, despite not being one of the contractual parties. This must be considered for EUDR compliance.

20. Labour rights * (Yes / No) 🚩

Promoting respect for labor rights is central to the mission of the United Nations Global Compact. Upholding workers' rights and adhering to labor standards are fundamental to ensuring decent work. Compliance with labor rights is also a key consideration within the context of the EUDR.

21. Human rights protected under international law * (Yes / No) 🚩

Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Everyone is entitled to these rights, without discrimination. International Human Rights Law lays down the obligations of Governments to act in certain ways or to refrain from certain acts, in order to promote and protect human rights and fundamental freedoms of individuals or groups. Compliance with human rights is also a key consideration within the context of the EUDR.

22. The principle of free, prior and informed consent (FPIC), including as set out in the UN Declaration on the Rights of Indigenous Peoples * (Yes / No) 🚩

The principle of Free, Prior and Informed Consent (FPIC) refers to the right of indigenous peoples to give or withhold their consent for any action that would affect their lands, territories or rights. It has to be taken into consideration within the EUDR context. As set out in the UN Declaration on the rights of indigenous peoples, contributes towards protecting biodiversity, mitigating climate change and addressing the related public interest concerns. Indigenous peoples possess traditional knowledge of ecological and medical value, and very often offer a model of sustainable use of forest resources. This can contribute to in-situ conservation, in line with the CBD. Furthermore, studies suggest that forest-dwelling indigenous peoples play a dual role in combating climate change: first, they normally resist the occupation and deforestation of the lands they have inhabited for generations; and second, some indigenous communities consider it their responsibility to protect the forests in order to mitigate climate change.

"Free" means that indigenous peoples' consent cannot be given under force or threat.
"Prior" indicates that indigenous groups must receive information on the activity and have enough time to review it before the activity begins.
"Informed" means that the information provided is detailed, emphasizes both the potential positive and negative impacts of the activity, and is presented in a language and format understood by the community.
"Consent" refers to the right of the community to agree or not agree to the project before it begins and throughout the life of the project.

23. Tax, anti-corruption, trade and customs regulations * (Yes / No) 🚩

Suppliers have to take tax, anti-corruption, trade and customs regulations of the country of origin into consideration when assessing compliance.

Source of information - Legislation

To ensure that the relevant products have been produced in compliance with the applicable legislation of the country of origin, proof must be provided. The form of this proof may vary depending on the specific regulation, but the source of the information must be clearly identified. Whether it is a confirmation, a questionnaire, or an audit from the producer, the key requirement is that the information can be verified.

What is your source of information to verify that the relevant products have been produced in accordance with the respective relevant legislation of the country of production?

Please describe for each regulation, in particular, the nature of the source, e.g.

> confirmation of the producer that relevant legislation was complied with

> questionnaire completed by the producer that shows compliance

> audit at the producer that shows compliance

> a different way (you will need to describe this)

24. Land use rights *

25. Environmental protection *

26. Forest-related rules, including forest management and biodiversity conservation, where directly related to wood harvesting *

27. Third parties' rights *

28. Labour rights *

29. Human rights protected under international law *

30. The principle of free, prior and informed consent (FPIC), including as set out in the UN Declaration on the Rights of Indigenous Peoples *

31. Tax, anti-corruption, trade and customs regulations *

32. Do you carry out risk assessment(s) as required by Article 10 EUDR, meaning verification and analyses that the information collected is in accordance with Article 9? * (Yes / No) 🚩

Operators need to verify and analyze information collected to proof that relevant products are deforestation free. Risk assessments should be carried out to establish whether there is a risk that the relevant products intended to be placed on the market or exported are non-compliant. Operators shall not place the relevant products on the market or export them, except where the risk assessment reveals no or only a negligible risk that the relevant products are non-compliant. The risks that have to be taken into account are listed in Article 10 Paragraph 2, it’s part of the next section of the questionnaire. The operators shall document and review the risk assessments at least on an annual basis and make them available to the competent authorities upon request.

Risk criteria

Operators must verify and analyze the information collected under Article 9, along with any other relevant documentation. Based on this information, they are required to conduct a risk assessment to determine whether there is a risk that the products intended for market placement or export are non-compliant. Operators are not permitted to place these products on the market or export them unless the risk assessment shows either no risk or only a negligible risk of non-compliance. Additionally, operators must document and review their risk assessments at least annually and make them available to the competent authorities upon request. They must also be able to demonstrate how the information was cross-checked against the risk assessment criteria and how the risk level was determined.

Which of the risk criteria mentioned in Article 10 Para. 2 EUDR do you take into consideration?

33. Risk of the relevant country of production or parts thereof according to the EU benchmarking system * (Yes / No)

This Regulation establishes a three-tier system for the assessment of countries or parts thereof. For that purpose, Member States and third countries, or parts thereof, shall be classified into one of the following risk categories: high risk: refers to countries or parts thereof, for which the assessment referred to in paragraph 3 results in the identification of a high risk of producing in such countries or in parts thereof, relevant commodities for which the relevant products do not comply with Article 3, low risk: refers to countries or parts thereof, for which the assessment referred to in paragraph 3 concludes that there is sufficient assurance that instances of producing in such countries or in parts thereof, relevant commodities for which the relevant products do not comply with Article 3, point (a), are exceptional and standard risk refers to countries or parts thereof which do not fall in either the category ‘high risk’ or the category ‘low risk’. This list will be published by the EU, not later than 18 month once the law comes into effect.

34. Presence of forest in the country / countries of production or parts thereof * (Yes / No)

Operators will need to establish whether the forest type prior to and including 31 December 2020 was primary forest or naturally regenerating forest (the two forest types to which the ‘forest degradation’ definition applies), then assess whether the forestry activities associated with wood harvesting, as well as planned post-harvesting activities.

35. Presence of indigenous peoples in the country / countries of production or parts thereof * (Yes / No)

if applicable, the existence, compliance with, or effective enforcement of laws protecting the rights of indigenous peoples

Forests provide subsistence and income to approximately one third of the world’s population and the destruction of forests has serious consequences for the livelihoods of the most vulnerable people, including indigenous peoples and local communities who depend heavily on forest ecosystems. The Commission should fully recognise the role and rights of indigenous peoples and local communities in protecting forests, taking into account the principle of free, prior and informed consent (FPIC).

36. The consultation and cooperation in good faith with indigenous peoples in the country / countries of production or parts thereof * (Yes / No)

When assessing the risk of non-compliance of relevant commodities and relevant products intended to be placed on the market or exported, violations of human rights that are associated with deforestation or forest degradation, including rights of indigenous peoples, local communities and customary tenure rights holders, should be taken into account.

37. The existence of duly reasoned claims by indigenous peoples regarding the use or ownership of the area used for the purpose of producing the relevant commodity * (Yes / No)

Given that the rights of indigenous peoples must be respected within the context of the EUDR, any substantiated claims they make should be given careful consideration and treated with the utmost seriousness.

38. Prevalence of deforestation or forest degradation in the country / countries of production or parts thereof * (Yes / No)

As the EUDR mandates that products be deforestation-free, it is crucial to assess the origin countries and the extent of their deforestation issues. Operators must ensure that products imported to or exported from the EU are free from deforestation. This should be done by verifying the origin of the products, including providing geodata for the plots where the products were cultivated.

39. Source, reliability, validity, and links to other available documentation of the information * (Yes / No)

If any relevant risk information is identified, it must be supported by a reliable and valid source. Therefore, the supplier must ensure that all criteria are met to ensure compliance.

40. Concerns in relation to the country / countries of production and origin or parts thereof * (Yes / No)

For example, level of corruption, prevalence of document and data falsification, lack of law enforcement, violations of international human rights, armed conflict or presence of sanctions imposed by the UN Security Council or the Council of the European Union

41. Complexity of the relevant supply chain and the stage of processing of the relevant products * (Yes / No)

in particular difficulties in connecting relevant products to the plot of land where the relevant commodities were produced

Operators and traders that are not SMEs are required to ensure that the required information on traceability that they supply to competent authorities in the Member States is correct, regardless of the length or the complexity of their supply chains. Traceability information can be added up along supply chains. For instance, a large, bulk shipment of soy that has been sourced in several hundred plots of land from several countries would need to be associated with a due diligence statement that includes all relevant countries of production and geolocation information for every single plot of land from all of these countries that have contributed to the shipment.

42. The risk of circumvention of the EUDR or of mixing with relevant products of unknown origin or produced in areas where deforestation or forest degradation has occurred or is occurring * (Yes / No)

There is no exception for the traceability requirement via geolocation. The operators also have to assess the complexity of the relevant supply chain and the risk of circumvention of the Regulation and the risk of mixing with products of unknown origin or origin in high-risk or standard-risk countries or parts thereof.

43. Conclusions of the meetings of the Commission expert groups supporting the implementation of the EUDR, as published in the Commission’s expert group register * (Yes / No)

To ensure equal participation in the preparation of delegated acts, the European Parliament and the Council receive all documents at the same time as Member States’ experts, and their experts systematically have access to meetings of Commission expert groups dealing with the preparation of delegated acts.

44. Substantiated concerns submitted under Article 31, and information on the history of non-compliance of operators or traders along the relevant supply chain with the EUDR * (Yes / No)

Article 31 allows individuals or entities to report concerns to authorities if they suspect non-compliance with regulations by operators or traders. Authorities must investigate these concerns promptly, including checks and hearings, and may take interim measures if necessary. The concerned parties must be informed of the outcome within 30 days. Additionally, the identity of those who submit concerns or conduct investigations must be protected in accordance with EU whistleblower protection laws.

45. Any information that would point to a risk that the relevant products are non-compliant * (Yes / No)

If a competent authority identifies a potential risk that this Regulation is being evaded—such as when a commodity or product from a high-risk country is processed in a low-risk country, and then placed on the market or exported with documentation falsely indicating it was produced in the low-risk country—the authority should conduct additional checks to assess potential non-compliance. If non-compliance is found, the authority should take appropriate actions, including seizing the relevant commodity or product, suspending its market placement or export, and conducting further investigations as necessary.

46. Complementary information on compliance with the EUDR * (Yes / No)

This may include information supplied by certification or other third-party verified schemes, including voluntary schemes recognised by the Commission and of the Council, provided that the information meets the requirements set out in Article 9 of this Regulation.

47. If you don't take into consideration all of the risk criteria mentioned above, please explain why (open question)

Source of information - Risk criteria

If any relevant risk criteria is identified, it must be supported by a reliable and valid source. The supplier must ensure that all criteria are met to ensure compliance.

What is your source of information to assess the respective risk criteria?

Please describe the source, index, report or information provided by the producer(s) that you rely upon for each risk criteria.

48. Risk of the relevant country / countries of production or parts thereof according to the EU benchmarking system * (open question)