00
Role determination
Who is named in the importer field of the customs declaration? Delivery terms are not decisive. The role arises per product flow, not per company.
Deliverable
- Role determination report (A / B / B+)
- Role table by flow
Compliance Service · methodology
Zero to ten: the 11-stage EUDR compliance roadmap
Not to explain the regulation, but to set out which work is done when and by whom. Every stage has a defined work item and a defined deliverable. Your role is determined first; the role decides which stages apply to you.
A
Third-country supplier EU buyer in the importer field. No DDS; the data pack that feeds the importer's DDS comes from you. Typical for Turkish exporters.
B
EU subsidiary as operator Your EU subsidiary in the importer field. The subsidiary carries full due diligence and the DDS; EORI required.
B+
Your company as operator Release for free circulation in your own name. You are the operator; the first EU seller is an operator too (Art. 7).
Staged implementation plan
Stages and deliverables
Stage 7 exists only in scenarios B and B+. The real workload sits in stages 2, 3 and 5.
01
Product scope mapping
Scope is decided by customs tariff code, not product name. Borderline items are classified one by one under the Combined Nomenclature rules. In composite products due diligence extends only to the relevant commodity.
Deliverable
- Scope matrix by product code
- Reasoned classification of borderline items
- Share of EU turnover in/out of scope
02
Supply chain and origin
Every layer the raw material passes through (forest enterprise, trader, cooperative, processor) and every country of origin. Türkiye is low risk; imported raw material carries its origin country's class. Mixed origin: each country separately.
Deliverable
- Chain map and origin inventory
- Country risk-class table
- Data ownership: which data sits in which layer
03
Geolocation infrastructure
Coordinates of all plots (WGS-84, ≥6 decimals); polygons above 4 ha. GeoJSON format, 10,000 production places / 25 MB per statement. Checked against open-source 2020 forest cover and post-2020 change maps.
Deliverable
- Geolocation pipeline and format template
- Plot verification report (inconsistencies, risk flags)
- Grouping strategy
04
Segregation and mixing control
Compliant raw material is kept separate from unknown-origin or non-compliant material at every stage. Mass balance is not accepted; if mixed, the batch fails. For silos/piles, everything since the last emptying must be declared.
Deliverable
- Written segregation procedure
- Storage and flow record system
- Compliance analysis of the existing certification model
05
Article 9 information file
Product description, quantity, country of production, geolocation and harvest period, parties, deforestation-free evidence, legality evidence (eight headings). For wood: scientific name and forest degradation. Delivered to the importer in scenario A; basis of the DDS in scenario B.
Deliverable
- Supplier EUDR Data Pack (TR/EN)
- Legality evidence set
- File architecture and retention plan (5 years)
06
Risk regime
If all raw material is from low-risk origins: Article 13 simplified due diligence; otherwise assessment against the 14 criteria of Article 10 and mitigation under Article 11. If risk cannot be reduced to negligible, the product cannot be placed on the market.
Deliverable
- Regime decision and reasoning
- Risk assessment framework
- Mitigation plan (additional documents, audits, supplier change)
07
Declaration and customs B / B+ only
Information System account, EORI, DDS submission, automatic risk profiling, reference number, entry on the customs declaration. A DDS may be rejected; grouping freezes the underlying statements.
Deliverable
- Information System registration
- DDS and grouping support
- Customs broker interface
08
Importer and supplier interface
Downstream: only the reference number and identity data; upstream: the basis of the whole file. The supplier contract gets data format, deadline, accuracy warranty, audit right and a no-mixing commitment. Response plan for substantiated concerns.
Deliverable
- Supplier data request template and contract clauses
- Importer data-pack format
- Substantiated-concern response procedure
09
Corporate system and records
Written due diligence system, annual independent review, compliance officer and internal audit for non-SME operators, annual public report (may sit inside CSRD). Three separate 5-year retention periods.
Deliverable
- Due diligence system documentation
- Review calendar
- Shared data model with CSRD
10
Calendar and monitoring
Obligations are tied to quantity and input changes, not shipments: new supplier, new plot, new origin, new product code, recipe change. Country classification and Annex I updates are monitored.
Deliverable
- Trigger table
- Legislation and country-class monitoring
- Annual data-pack update
Service map
Which work item matches which stage
TDiagnosisKSet-upSOngoing
| Stage | Topic | Work item |
|---|---|---|
| 0 | Role | T1 Scope and Role Determination Report |
| 1 | Product scope | T2 Tariff Classification and Scope Matrix |
| 2 | Supply chain | K1 Chain Mapping and Origin Inventory |
| 3 | Geolocation | K2 Geolocation Pipeline and Plot Verification |
| 4 | Segregation | K3 Segregation Procedure · T3 Certification Model Compliance Analysis |
| 5 | Information file | K4 Article 9 File / Supplier EUDR Data Pack |
| 6 | Risk regime | K5 Article 10 Risk Assessment Framework and Article 11 Mitigation Plan |
| 7 | Declaration and customs | K7 Information System Registration, DDS and Grouping Support (B / B+) |
| 8 | Supplier interface | K6 Supplier Data Request and Contract Architecture |
| 9 | Corporate system | K8 Due Diligence System Set-up · S2 Annual Review |
| Interim | Triggers | S3 Data Pack Update · S4 Substantiated-Concern Response |
| 10 | Calendar and monitoring | S1 Legislation and Country Classification Monitoring |
Sector differences
Same roadmap, different centres of gravity
Wood, panels, paper, furniture, pallets
- Simplified regime (Art. 13) for Turkish-origin wood; origin-country risk for imported timber and pulp.
- Additional criterion: forest degradation. Scientific species name mandatory in the DDS.
- Legality: OGM sales documents, forest-product transport permits, private forest/afforestation permits.
- Micro/small operators also bound by 30 December 2026; no transitional exemption (former Timber Regulation scope).
- Pallets sold as a product (4415) in scope; pallets used as packaging out of scope.
Cocoa and chocolate
- 1806 in scope, 1905 (biscuits, wafers, cakes) out; the portfolio split sets the burden.
- Origin countries are standard risk: full regime is the only route. No separate due diligence for palm oil.
- Geolocation data sits in the trader layer; the real work is the supplier contract and data-request architecture.
- Mass balance is not accepted; physical segregation mandatory, mixed batches fail.
- Genuine transitional period: cocoa placed on the EU market before 30 December 2026 is exempt; proof is the customs declaration.
Coffee, rubber, soya, palm
- Origins are mostly standard risk; full regime and 14-criteria assessment.
- Thousands of small plots: points suffice below 4 ha; DDS grouping for the volume limit (10,000 production places / 25 MB).
- Draft delegated act: instant coffee and some palm derivatives being added; monitoring needed.
- Mixed origin: each country entered and assessed separately in the DDS.
Let's start with scope
The scope and role determination frames every following step. It is free.
Application
Compliance service application
The free preliminary assessment takes three steps: contact, subject and confirmation.