Who files an EUDR due diligence statement, and what goes in it?

Why the geolocation is where it goes wrong

The information system accepts a statement only with coordinates for every plot. For a commodity grown by thousands of smallholders and mixed in a cooperative's warehouse, that means collecting polygons and points at farm level, before the shipment is sold.

Mixing is itself a risk factor.

Article 10(2)(j) lists "mixing with relevant products of unknown origin" among the criteria in the risk assessment, so a lot that is mostly traceable is not traceable. If the assessment finds a risk that is not negligible, Article 11 requires mitigation until it is, and Article 4(4)(b) bars placing the product on the market before then.

Where you file, and who checks in the Netherlands

Statements and simplified declarations go into the EUDR information system, which the Commission runs within TRACES. The system registers each statement with a reference number (Article 33(2)), and the Commission's TRACES FAQ adds a verification number for security. Statements bundled under a grouped declaration cannot be withdrawn or amended one by one while that declaration is active. In the Netherlands the minister is the competent authority under the Dutch implementing act (Stb. 2024, 242). Government guidance for businesses says the NVWA can check you and the Douane checks goods and statements, with importers passing the reference numbers to customs. The NVWA can impose an order subject to a penalty, and fines run through the Omgevingswet. An Eerste Kamer committee note records that adapting the Dutch implementing law to the 2025 amendment will take about one to one and a half years.

What enforcement and the review showed

Article 16 of the EUDR sets the minimum share authorities must check every year: at least 9% of the quantity of each product from high-risk countries, 3% of operators for standard risk and 1% for low risk. Since the 2025 amendment those rates cover non-SME downstream operators and traders too, and checks may come without warning.

Penalties under Article 25(2) of the EUDR include a maximum fine of at least 4% of total annual EU turnover, confiscation of products and revenues, and exclusion from public procurement for up to 12 months.

The Commission's simplification review of 4 May 2026 estimates that the 2025 changes cut the cost of compliance by about 75%, from EUR 8.1 billion to EUR 2.0 billion a year. It concluded that further amendment of the basic text is not appropriate.

Scope changes came instead through Delegated Regulation (EU) 2026/2102, which removes cattle hides, skins and leather and retreaded tyres, and adds products such as soluble coffee from 30 December 2027.