This checklist helps EU importers verify whether evidence provided by their palm oil suppliers is sufficient to support a defensible Due Diligence Statement before filing. Unlike exporter-oriented checklists that guide evidence collection, this template focuses on the importer's verification obligation: assessing the completeness, consistency, and credibility of evidence you receive.
Under Article 4, the EU importer bears primary legal liability. If a competent authority challenges your DDS and the underlying supplier evidence is weak, the penalty exposure falls on you — up to 4% of EU-wide annual turnover. Palm oil's extensive FFB aggregation at the mill makes plot-level traceability verification the central challenge for importers.
What is the EU importer's verification obligation?
Regulation 2023/1115 requires the operator placing palm oil on the EU market to exercise due diligence encompassing information gathering, risk assessment, and risk mitigation (Article 8). The importer cannot delegate this obligation to suppliers, refineries, or traders. Even where upstream actors have collected geolocation data and documented legality, the importer must independently assess whether that evidence is sufficient and credible.
Palm oil supply chains span 4-5 tiers: smallholder or estate to FFB collection, collection to mill, mill to refinery, refinery to exporter, exporter to EU importer. A single mill may source from hundreds of smallholders. The importer must verify that traceability survives this aggregation — that each batch reaching the EU can be linked to specific source plots.
What this template covers
Supplier documentation review
- Confirm supplier has provided a complete evidence package — not a summary, RSPO certificate, or self-certification
- Verify evidence covers every source plot contributing FFB, including both estate and smallholder sources
- Check that evidence is dated and version-controlled — reject undated documents
- Confirm all intermediaries (FFB collectors, mills, refineries, traders) are identified by name
- Verify evidence extends below the mill to individual plots — refinery-level traceability alone is insufficient
- Confirm attestations are signed by an authorised representative
Red flags: RSPO certificate as sole evidence. Traceability stops at the mill without individual plot data. Supplier states "full traceability to mill" without demonstrating mill-to-plot links.
Geolocation data verification
- Verify coordinates are field-captured (not estimated), in WGS84/EPSG:4326, at 6-decimal precision, with collection timestamps and device metadata
- Confirm GPS points for plots under 4 hectares; polygon boundaries for plots exceeding 4 hectares (Article 9(1)(d))
- Cross-check a sample of coordinates against satellite imagery to confirm oil palm at stated locations
- Verify collection timestamps are plausible — not years before the consignment date
- Confirm each plot links to an identified farmer, estate owner, or concession holder — not just a mill name
- For large estates: verify polygons correspond to planted area, not the full concession including conservation zones
Red flags: Round-number coordinates — likely estimated. Multiple plots sharing identical coordinates — copy-paste data. Geolocation at mill level only. Coordinates resolve to areas without visible oil palm canopy.
Deforestation-free evidence assessment
- Verify deforestation screening against the December 31, 2020 cutoff using satellite imagery at sufficient resolution for each source plot
- Confirm screening methodology is documented: data sources, resolution, thresholds, and decision criteria
- Check that independent alert systems (e.g., Global Forest Watch, RADD, Nusantara Atlas) were cross-referenced
- Verify peatland overlap screening: source coordinates cross-referenced against published peatland maps
- For plots near the cutoff or in high-conversion areas: verify time-series analysis, not a single snapshot
- Confirm planting year or replanting date recorded and consistent with the deforestation-free claim
Red flags: RSPO cited as sole deforestation-free evidence — RSPO does not use the December 31, 2020 cutoff. No peatland overlap analysis for Indonesian or Malaysian origins. Aggregate screening for a mill catchment instead of plot-level screening.
Legality evidence assessment
- Verify supplier identified relevant legislation of the country of production — not just "all laws complied with"
- Confirm tenure documentation for each plot — concession licence (HGU/IUP for Indonesian origins), estate title, or smallholder land records
- For Indonesian origins: verify documented compliance with the moratorium on new permits in primary forests and peatlands
- Verify permits and export authorisations are current and match the consignment period
- Check legality evidence covers all categories under Article 9(1)(e): land use, forestry, environmental protection, labour, tax, and third-party rights including FPIC
Red flags: Expired HGU/IUP permits. Legality evidence covers land use but omits labour or environmental compliance. NDPE policy cited as legal evidence — NDPE is a voluntary commitment, not legal documentation.
Processing and traceability verification
- Verify OER documentation at mill level — confirm the stated rate (typically 20-23% FFB to CPO) is supported by measurement methodology, not an industry average
- Confirm mill-level traceability: each CPO batch linked to specific contributing source plots, not just the mill
- Check FFB collection records document contributing smallholders and estates for each delivery
- Verify refinery intake reconciled against outbound volumes within documented tolerance
- Confirm batch identifiers maintained from mill through refinery and exporter with traceability links at each transfer
- Verify no mass balance applied — EUDR requires physical segregation or identity preservation (Article 9)
Red flags: Reconciliation gaps exceeding 5% without explanation. OER cited as "industry standard 22%" without mill-specific documentation. Traceability to mill but no link from CPO batches to specific smallholder FFB deliveries.
Risk assessment and DDS readiness
- Perform your own risk assessment — do not rely solely on the supplier's assessment (Article 10)
- Document your methodology: how you evaluated evidence, thresholds applied, and decision criteria
- Assess mill supply base complexity — mills sourcing from hundreds of smallholders require proportionate plot-level evidence
- Where your assessment identifies concerns the supplier did not flag, require additional evidence before filing
- Confirm all DDS fields under Article 4(2) can be populated from the evidence package
- Verify evidence archived for the 5-year retention period (Article 12)
- Confirm end-to-end auditability: competent authority can trace from DDS to individual plots through each aggregation stage
Red flags: "Negligible risk" for a high-risk origin without justification. Mill sources from 200+ smallholders but plot-level evidence covers only a fraction. No version control or audit trail.
How to use this template
Step 1 — Request the full evidence package. Specify that evidence must extend below the mill to individual source plots. Include geolocation format, peatland screening, and FFB collection record requirements in purchase contracts. For palm oil, start with mill-level sourcing data — evidence that covers only the refinery without individual mill and estate documentation is insufficient.
Step 2 — Verify each section. Mark items complete only when independently verified — not when the supplier has confirmed verbally.
Step 3 — Document your verification. Record the date, evidence examined, and your conclusion for each item. This documentation is part of your due diligence and must be retained five years.
Step 4 — Decide before filing. If red flags remain unresolved, do not file the DDS. Filing on weak evidence creates greater legal exposure than delaying.
How to implement this in your organisation
Assign ownership. Your EU compliance officer owns the checklist end-to-end, from receiving the supplier evidence package through to the filing decision. Procurement acts as the first filter, performing a completeness check on each incoming package before forwarding it for substantive review. An internal auditor should review the compliance officer's verification work at least annually to confirm procedures are followed consistently.
Set the review cadence. Run this checklist for every consignment before filing the DDS — per-consignment review is non-negotiable. Conduct a full supplier re-assessment annually, and trigger immediate re-verification whenever a supplier reports changes to their source plots, mill catchment areas, or intermediary chain. Verify mill-level sourcing data whenever FFB catchment areas shift seasonally, as smallholder contributions to a given mill change with harvest patterns and road conditions.
Define your escalation path. Any red flag identified during verification pauses the DDS filing immediately. Procurement holds the next payment milestone until the issue is resolved. If a red flag remains unresolved within 30 days, escalate to the head of compliance or legal counsel. Document every escalation, including the date raised, parties involved, and resolution or outcome.
Connect to existing workflows. Embed the evidence specification directly in purchase contracts so suppliers know what to provide before shipment — particularly the requirement for plot-level data below the mill. Gate customs release on checklist sign-off — no signed-off checklist, no release authorisation. Integrate the QC inspection at port with the verification process so that physical checks on consignment quality and documentation review happen in a coordinated sequence rather than as separate workflows.
Who needs this template
- EU importers placing palm oil or derivatives on the EU market who must verify supplier evidence before filing their DDS
- Compliance officers assessing whether upstream evidence — particularly mill-to-plot traceability — meets the standard for a defensible filing
- Procurement managers evaluating whether current suppliers can provide EUDR-grade evidence, and whether contracts need to mandate specific evidence deliverables
- Internal auditors reviewing verification procedures before competent authority inspections
FAQ
Does RSPO certification satisfy my verification obligation?
No. RSPO does not require WGS84 geolocation at 6-decimal precision, does not use the December 31, 2020 cutoff, and does not produce a DDS. RSPO evidence may support your assessment but cannot replace EUDR due diligence.
My supplier provides traceability to mill — is that sufficient?
No. Article 9(1)(d) requires traceability to the plot of land where the commodity was produced. Each smallholder and estate contributing FFB must be individually geolocated and linked to the CPO batch in your consignment.
What role does peatland screening play in my verification?
Peatland drainage and conversion are subject to legal restrictions in major producing countries. Source plots overlapping published peatland maps require verification of compliance with applicable restrictions. Peatland overlap also increases the probability that land conversion occurred, which is relevant to your deforestation-free assessment.
What if the supplier evidence has gaps but the consignment has already shipped?
Do not file the DDS until gaps are resolved. If they cannot be closed, you face a choice: reject the consignment, apply enhanced mitigation with documentation, or accept the exposure of filing on incomplete evidence.
Palm oil supply chains involve extensive FFB aggregation at the mill, making plot-level traceability the hardest verification challenge for EU importers. A checklist identifies what to check — a platform makes verification systematic. Book a demo to see how ResourceLedger helps EU importers assess supplier evidence against EUDR requirements before every DDS filing.