EUDR Compliance Checklist for Food and Beverage Importers: Step-by-Step Guide

Step 1: Product Scoping — Which of Your Products Are Covered#

The first step is identifying which of your imported products contain one or more of the seven EUDR commodities: cattle and beef, cocoa, coffee, palm oil, soya, wood, or rubber. For food and beverage importers, the most common covered inputs are cocoa (in chocolate and confectionery), coffee, palm oil (in bakery products, snacks, spreads, and ready meals), and soya (in animal feed derivatives, tofu, and processed foods). Check Annex I of EUDR Regulation 2023/1115 against the CN codes of all your imported products. Many composite food products contain multiple covered commodities — a biscuit may contain palm oil, cocoa, and soya simultaneously, each requiring separate EUDR due diligence. Create a complete inventory of covered products and the commodities they contain.

Step 2: Supplier Mapping to Production Country and Farm Level#

For each covered commodity in your supply chain, map from your direct supplier back to the country of production and, ultimately, to the farm or plantation level. This typically involves: identifying your direct (Tier 1) commodity suppliers and the countries from which they source; asking them to disclose their own supply chain — the traders, processors, and cooperatives from which they buy; and tracing to the country and region of production. For commodities like palm oil, suppliers often source from multiple origins and you may need to request an origin breakdown by volume for each lot. For cocoa and coffee, the cooperative or farmer organisation level is typically the aggregation point where individual farm identification can occur. Document every link in this chain — the due diligence system must be able to demonstrate that you have made reasonable efforts to establish the full supply chain.

Step 3: Collecting Geolocation and Land-Use Data#

Geolocation data collection is the most technically demanding step. For each production country and region identified in Step 2, you must obtain GPS polygon coordinates for the plots of land where the commodity was grown. For cooperatives or farmer organisations that have already conducted geolocation mapping (as part of certification schemes or government programmes), request the geolocation dataset in a standard format — GeoJSON or shapefile are the most compatible with EU due diligence system requirements. For supply chains without existing geolocation data, you must either commission field mapping programmes or work with your supplier to implement them. In addition to coordinates, you need evidence that the land was not forested after 31 December 2020 — typically through satellite imagery cross-referencing against Global Forest Watch or equivalent monitoring data.

Step 4: Risk Assessment and Risk Mitigation#

EUDR requires operators to conduct a risk assessment for each supplier and commodity combination. The assessment must consider: the country and region of production (against the EU country risk benchmarking when published), the commodity (some carry higher deforestation risk than others by nature), the reliability of geolocation data (self-reported versus independently verified), the supplier's track record, and satellite monitoring evidence for the specific plots identified. Where the risk assessment identifies non-negligible risk, operators must implement risk mitigation measures before placing goods on the market — this could include additional supplier auditing, independent verification of geolocation data, or switching to alternative compliant supply sources. The risk assessment and mitigation measures must be documented in the operator's due diligence system, which is subject to competent authority inspection.

Step 5: Due Diligence Statements and Operator Registration#

Before each shipment of covered goods enters the EU, the operator must submit a due diligence statement through the EU EUDR Information System and obtain a reference number. This reference number must be included in customs documentation at import. EU operators must register with the EUDR Information System — the platform was being rolled out in stages during 2024. The due diligence statement covers: the operator's identity and EORI number, product type and CN code, quantity, country of production, geolocation data, the risk assessment conclusion (negligible risk), and a description of due diligence measures. Statements may be submitted by the operator directly or by a third-party representative. AskBiz tracks the EUDR Information System registration process, country risk benchmarking decisions, and deadline updates so you can manage your compliance programme against current requirements.

• EUDR compliance for food and beverage importers involves five main steps: identifying which products contain covered commodities; mapping suppliers to farm level; collecting geolocation and land-use data; conducting a risk assessment; and submitting due diligence statements before shipments enter the EU.
• The December 2025 deadline requires starting the process now.