EUDR for importers

Are EU importers operators under the EUDR?

When a relevant product is imported into the EU and placed on the market for the first time, the importer can be the upstream operator. The exact role depends on the transaction, so role identification should happen before the rest of the workflow.

Importer workflow

1. Confirm product scope. Check the exact CN/HS code against current Annex I.
2. Identify country of production. Country benchmarking affects the due-diligence path but does not replace information collection.
3. Collect Article 9 information. Product, quantity, supplier/customer, production country, production date or time range where relevant, geolocation, legality and deforestation-free evidence.
4. Assess risk. Reach no or negligible risk before the relevant placing/export step where the regulation requires it.
5. Mitigate risk where needed. Add information, verification or other controls where risk is more than negligible.
6. Use the Information System. Submit the applicable declaration through the official EUDR system.

What should importers request from suppliers?

• Exact product description and CN/HS code.
• Country and production-location information.
• Geolocation of relevant plots or cattle establishments.
• Production date or time range where relevant.
• Supplier / producer identification.
• Evidence supporting legality and deforestation-free status.
• A clear link between the evidence and the product batch.

Common importer mistakes

Common workflow problems include using an outdated scope list, assuming low-risk origin means no information collection, accepting coordinates without checking the correct production area, and treating certification as a substitute for the operator's own due diligence.