EUDR for exporters

When does an exporter become the operator?

For relevant products exported from the EU, due diligence is required when the product is not already covered by upstream due diligence. The exact role depends on the transaction, so exporters should confirm whether they are acting as the upstream operator for that export.

Exporter checklist

1. Confirm that the product is listed in Annex I.
2. Identify whether upstream due diligence already exists for the relevant product.
3. Collect required product, origin, supplier and geolocation information.
4. Apply the applicable risk-assessment and mitigation process.
5. Submit the required declaration in the Information System before export.
6. Retain supporting records.

What if you export a processed product?

Processed or manufactured products can still be relevant if their CN code is in Annex I. Confirm the exact current code and whether an “ex” limitation applies.