MRV Carbon and Deforestation


EUDR Frequently Asked Questions: 10 Updates

January 4, 2024

Written by

Caroline Busse

Polygon and not Circumference

For plots of land over four hectares (for commodities other than cattle), geolocation has to be provided using polygons (not a unique central point with a circumference). (Question 13)

Excess Plots

If the operator declares ‘in excess’ in the due diligence statement, the operator assumes full responsibility for compliance of ALL plots of land for which geolocation is provided, regardless of whether such plots of land are concerned by the production of commodities/products placed on the market. If one plot of land ‘geolocalised’ in the due diligence statement is not compliant, the entire set of plots of land ‘geolocalised’ is non-compliant. (Question 15)

CN and HS Codes

The "HS Nomenclature" is an international multipurpose nomenclature under the World Customs Organization (WCO). This nomenclature assigns six-digit codes to classify goods and applies worldwide. Countries/ regions can add additional numbers to the HS Nomenclature for more detailed classification. The Combined Nomenclature (CN code) of the EU is an eight-digit commodity code that further subdivides the HS Nomenclature into more specific goods. The CN code is the basis for the declaration of goods for import into or export from the EU. (Question 34)

Negligible Risk

Negligible risk’ refers to the level of risk of relevant products to be placed on the market or exported, where, on the basis of a full assessment of product-specific and general information, and, where necessary, of the application of the appropriate mitigation measures, those commodities or products show no cause for concern as to not being in compliance.

Operators and traders may only conclude ‘negligible risk’ (which is a pre-condition for placing or making available on the market or exporting relevant products) as a result of conducting due diligence. The ‘negligible risk’ element does not apply to commodities (there is no ‘risk status’ per commodity in the Regulation). (Questions 58-60)

Team Europe Initiative

The Team Europe Initiative (TEI) Hub (“Zero Deforestation Hub”) will provide information and outreach to partner countries on deforestation-free value chains and will conduct knowledge-management to coordinate relevant pre-existing projects from EU and Member States. The Sustainable Agriculture for Forest Ecosystems (SAFE) project is the most important pillar of the TEI. SAFE is currently being implemented in Brazil, Ecuador, Indonesia and Zambia. Further country components will be added in Vietnam and DRC in 2024. The SAFE project will be further scaled up to cover more countries through upcoming financial contributions from Member States. The Technical Facility on Deforestation-free Value Chains will be a flexible and on-demand instrument to assist producing countries with expertise on technical requirements, such as geolocalization, land-use mapping and traceability, with a focus on smallholders. (Questions 66-68)

Registration via EORI Number

Operators/traders that import or export relevant commodities and products need to provide their Economic Operators Registration and Identification (EORI) number when registering in TRACES NT. Domestic operators/traders, who do not have an EORI number may register through one of the other identifiers supported by TRACES such as VAT number, National Company Number or Taxpayer Identification Number. (Question 73)

Provision of Geolocation Data

Operators/traders will be able to Import geolocation data through an ‘import’ button in the EU Information System via standardized file formats such as the GeoJSON format. (Question 74)

Amendment of Due Diligence Statement

Cancellation or amendment of a submitted Due Diligence Statement will be possible within 72 hours after the due diligence reference number has been provided by the System. Cancellation or amendment will not be possible if the DDS reference number has already been used in a custom declaration, in another DDS, or if the corresponding product has already been placed or made available on the market or exported. (Question 76)

Transitional Period

Operators/traders need to follow certain requirements when placing relevant commodities and products on the market during the transitional period (between the entry into force and application of the Regulation). The FAQs note three example scenarios: (Question 80)

1. If a commodity is placed on the market during the transitional period (before 30/12/2024,) and is used to produce a relevant derived product, which is placed on the market after 30/12/2024, the obligation of the operator/trader will be limited to gathering evidence to prove that the commodity used to produce the product was placed on the market before the entry into application of the Regulation.

2. If a relevant product is placed on the market during the transitional period, but is then used to produce another derived product which is placed on the market by a downstream operator after 30/12/2024,the obligation of the operator will be limited to gathering evidence to prove that the relevant derived product was placed on the market before the entry into application of the Regulation. For parts of the final relevant product that have been produced with other relevant products placed on the market after 30/12/2024, the operator/trader will be subject to the standard obligations of the Regulation.

3. An operator places on the market a relevant commodity or a product in the transitional period, which is then ‘made available’ on the market by one or more non-SME traders after 30/12/2024. In this scenario, the obligations of the non-SME trader will be limited to gathering adequately conclusive and verifiable evidence to prove that such relevant commodity, or relevant product, was placed on the market before the entry into application of the Regulation.

EU Observatory on Deforestation and Forest Degradation

The EU Observatory on deforestation and forest degradation will cover all forests worldwide.

The primary purpose of reference maps produced by the EU Observatory will be to inform the risk assessment by operators/ traders. As such, reference maps will have the following features: (Question 84)

  • They will be non-mandatory. There will be no obligation compelling operators /traders to use the reference maps of EU Observatory to inform their risk assessment
  • They will be non-exclusive. Operators/ traders may apply other maps that can be more granular or detailed than those made available by the Observatory
  • They will be non legally binding. Reference maps from the EU Observatory may be used for risk assessment. However, the fact that geolocation falls within an area considered as forest does not automatically lead to non-compliance. On the other hand, if geolocation falls outside an area considered as forest the shipment/commodity does not mean that it will not be checked or that the commodity will be automatically compliant (due to the absence of 100% accuracy, and because a deforestation-free commodity could anyway be illegal)

Further updates from the EU Commission are planned for Q1 2024.

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About the author

Caroline Busse


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Caroline is an experienced data scientist with a management degree from TU Munich and a degree in earth observation from the University of Würzburg, which is co-chaired by the German Aerospace Center (DLR). She has worked as a data scientist in the areas of nature conservation and land use change monitoring at WWF, the German Centre for Integrative Biodiversity Research (iDiv), and at tech companies such as Celonis and Deloitte.


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