EUDR Due Diligence Explained: A Step-by-Step Checklist for Importers

Category: Certification & Compliance Center Primary Keywords: EUDR due diligence; due diligence statement; EUDR checklist forimporters

Introduction: The Due Diligence Statement Is an Outcome, Not a Form

A common misunderstanding among plywood and wood panel importers is treating the EUDR due diligence statement (DDS) as a single form to fill out - something a compliance officer completes in an afternoon and files away. In reality, the DDS is the final output of a structured three-step process defined under Regulation (EU) 2023/1115: information collection, risk assessment, and risk mitigation (European Commission, Green Forum - Understand Due Diligence). Skipping straight to "filling out the statement" without genuinely working through the first two steps is how importers end up submitting technically complete but substantively weak documentation - the kind that draws scrutiny during a customs check.

This guide breaks EUDR due diligence into its three components as the regulation actually structures them, then translates that into a practical due diligence checklist for importers preparing their first (or fiftieth) EUDR-linked shipment of certified wood panels into the EU.

Step 1: Information Collection

The first pillar of due diligence, addressed under Article 9 of the regulation, requires operators to gather a specific set of information about the product before any risk assessment can meaningfully happen (Coolset - EUDR Due Diligence Requirements Explained). For a plywood or engineered wood panel shipment, this typically includes:

A description of the product and, for wood, the trade name and species Quantity of the product (volume, weight, or units, depending on the product type) Country and, where relevant, region of production

Geolocation coordinates of the plot(s) of land where the wood was harvested - the single most operationally demanding item on this list, particularly for composite products like plywood that may combine veneer sourced from multiple harvest locations

Confirmation of legal compliance with the country of production's applicable laws

Supplier and supply chain information sufficient to trace the product back to its origin

This step is where most of the actual legwork happens, and it's also where supplier cooperation becomes essential - an importer cannot manufacture geolocation data or origin documentation on their own; it has to come from the supply chain itself. Practical guides for smaller operators consistently flag this as the step requiring the earliest start, since gathering this data from unprepared upstream suppliers is often the slowest part of the entire process (osapiens - EUDR Due Diligence in Practice: A Step-by-Step Guide for SMEs).

Step 2: Risk Assessment

Once the information is collected, the operator must assess whether there is a risk that the product is not deforestation-free or not legally produced. This isn't a binary pass/fail check - it's a documented evaluation weighing multiple factors, including the country and region's risk classification (low, standard, or high, per the EU's benchmarking system), the prevalence of deforestation or forest degradation in the specific sourcing area, the complexity of the supply chain, and the reliability of the information gathered in Step 1.

The goal of this step is to reach a defensible conclusion about whether the risk is negligible - a specific legal threshold under the regulation, not a subjective "seems fine" judgment (Trusty - EUDR Due Diligence Requires Risk Assessment, Not Just Data Collection). Operators sourcing from regions or suppliers with weaker traceability records, or from countries classified as higher risk, should expect this step to require more extensive verification before a negligible-risk conclusion can be reasonably supported - and should document that verification, since regulators can request evidence of how the risk assessment was actually conducted, not just its conclusion.

Step 3: Risk Mitigation and Statement Submission

If the risk assessment identifies anything more than a negligible risk, the operator must take "adequate procedures and measures" to reduce that risk to negligible before the product can be placed on the EU market, as required under the regulation's risk mitigation provisions (Meridia - EUDR Compliance Guide). This can include requesting additional supporting documentation from suppliers, conducting independent verification of specific claims, or in some cases sourcing an alternative supply for that particular shipment.

Once the operator can support a negligible-risk conclusion - either because the initial assessment found no significant risk, or because mitigation measures successfully reduced an identified risk - the due diligence statement itself is submitted through the EU's centralized Information System, the digital platform where all DDS filings are logged (European Commission - The Information System of the EU Deforestation Regulation).

What Happens After Submission: Reference Numbers vs. Verification Numbers

This is a detail that trips up importers handling their first few EUDR-linked shipments: the system generates more than one identifying number, and they serve different purposes. Upon submission and approval of a DDS, the system generates a reference number unique to that specific declaration (Trusty.id - EUDR Compliance: Guide to the Due Diligence Statement). This reference number, along with an associated verification number, must accompany the shipment's customs declaration and be shared with downstream buyers - creating a traceable link between the physical shipment and its underlying due diligence work throughout the rest of the supply chain (Impact Buying - EUDR Due Diligence: How to Prepare, Document and Submit).

For every shipment moving through customs, this reference number is what a customs authority checks - meaning a lost, mistyped, or mismatched reference number can hold a shipment just as effectively as a missing due diligence statement altogether. Building a simple internal log connecting each shipment to its DDS reference and verification number is a small administrative step that prevents a genuinely disproportionate amount of downstream friction.

Every approveddue diligence statement generates a reference numberthat musttravel with the shipmentthrough customs and be shared with downstream buyers.

A Practical Due Diligence Checklist for Wood Panel Importers

Bringing the three-step process down to an actionable list:

Product description, species, and quantity documented for the specific shipment

Geolocation coordinates obtained for all relevant harvest plot(s), including composite/multi-origin products

Country and regional risk classification checked against current EU benchmarking data

Legal compliance documentation obtained for the country of production

Risk assessment conducted and documented, with a clear negligible/non-negligible conclusion

Mitigation measures applied and documented, if the initial risk assessment identified any concern

Due diligence statement submitted through the EUDR Information System

Reference number and verification number recorded and linked to the specific shipment

Reference number shared with downstream buyers and included in the customs declaration

Making This Process Easier: What to Ask Your Supplier

The single biggest lever an importer has for making this process faster and less error-prone isn't a better internal workflow - it's working with suppliers who already have geolocation and legality documentation organized and ready to share, rather than scrambling to produce it order by order. A supplier that can hand over complete Step 1 information within days, rather than weeks, effectively compresses the entire due diligence timeline on the importer's side.

As a manufacturer holding FSC, CARB P2, EPA, and JAS certifications across its product range, WADA GROUP maintains organized origin and compliance documentation for its plywood, LVL, and panel production, so buyers preparing EUDR due diligence statements can move directly into risk assessment rather than spending weeks chasing basic sourcing information from the factory.