This checklist helps EU importers verify whether evidence provided by their rubber 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.
What is the EU importer's verification obligation?
Regulation 2023/1115 requires the operator placing rubber 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. Even where upstream actors have collected geolocation data and documented legality, the importer must independently assess whether that evidence is sufficient and credible.
Rubber supply chains involve 3-5 aggregation tiers between smallholder and EU port of entry. Each tier introduces traceability risk. The importer's task is to verify that evidence survives every aggregation point — not merely to confirm evidence exists at the first tier.
What this template covers
Supplier documentation review
- Confirm supplier has provided a complete evidence package — not a summary or self-certification
- Verify evidence covers every source plot contributing to the consignment, not a representative sample
- Check that evidence is dated and version-controlled — reject undated documents
- Confirm all intermediaries (collectors, processors, exporters) are identified by name between source plots and your delivery
- Verify attestations are signed by an authorised representative — not a sales contact
Red flags: One-page summary instead of underlying evidence. "All data is in our system" but cannot be exported. Evidence omits one or more aggregation tiers.
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 rubber trees at the stated locations
- Verify collection timestamps are plausible — not years before the consignment date
- Confirm each plot links to an identified farmer or landholder, not just a collector name
Red flags: Round-number coordinates (e.g., -2.500000, 101.000000) — likely estimated. Multiple plots sharing identical coordinates — copy-paste data. Coordinates resolving to water, roads, or urban areas.
Deforestation-free evidence assessment
- Verify deforestation screening against the December 31, 2020 cutoff using satellite imagery at sufficient resolution
- Confirm screening methodology is documented: data sources, resolution, thresholds, and decision criteria
- Check that independent alert systems (e.g., Global Forest Watch, RADD) were cross-referenced — not a single tool
- For plots near the cutoff: verify time-series analysis, not a single snapshot
- Confirm planting year is recorded and consistent with the deforestation-free claim
Red flags: Certification (PEFC, FSC) cited as sole deforestation-free evidence — certifications do not replace due diligence. Imagery older than 12 months. No methodology documentation.
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 — formal title, or village head attestations and customary rights records where formal title is absent (critical for Indonesian smallholders)
- For Thailand-origin: confirm low-risk classification is documented but full due diligence performed — low-risk reduces inspection frequency (1% vs 9%), not the obligation
- 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 permits. Legality evidence covers land use but omits labour or tax. "Industry standard practice" cited as legality evidence.
Processing and traceability verification
- Confirm DRC conversion ratios documented with sampling methodology — reject reconciliations without documented factors (28-35% latex; 45-55% cup lump)
- Verify wet-to-dry-weight conversion applied consistently with tolerance ranges stated
- Check volume reconciliation at each tier falls within tolerance — require explanation for gaps exceeding 5%
- Confirm multi-tier aggregation is traceable: where 2-3 collectors feed a processor, each collector's plots link to the batch
- Verify batch identifiers maintained from processor through exporter with traceability links at each transfer
- Confirm no mass balance applied — EUDR requires physical segregation or identity preservation (Article 9)
Red flags: Reconciliation gaps exceeding 5% without explanation. Traceability covers processor-to-exporter only, omitting smallholder-to-collector tier. Conversion factors cited without sampling protocol.
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
- 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" conclusion for a high-risk origin without justification. No version control or audit trail. Evidence unavailable in a format you can archive independently.
How to use this template
Step 1 — Request the full evidence package. Specify format and content requirements in purchase contracts to avoid incomplete packages after shipment. For rubber, focus first on DRC conversion documentation — volume reconciliation gaps are the most common red flag in rubber supply chains.
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 — there is no safe shortcut for skipping a per-consignment review. Conduct a full supplier re-assessment annually, and trigger immediate re-verification whenever a supplier reports changes to their source plots, processing facilities, or intermediary chain.
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. Gate customs release on checklist sign-off — no signed-off checklist, no release authorisation. Link DRC reconciliation checks to the quality inspection already performed at port, where weight and moisture measurements are standard procedure, to avoid duplicating effort while strengthening evidence review.
Who needs this template
- EU importers placing rubber on the EU market who must verify supplier evidence before filing their DDS
- Compliance officers assessing whether upstream evidence meets the standard for a defensible filing
- Procurement managers evaluating whether current suppliers can provide EUDR-grade evidence, and whether contracts need amendment
- Internal auditors reviewing verification procedures before competent authority inspections
FAQ
Can I rely on my supplier's DDS filing instead of my own verification?
No. Under Article 4, the operator placing the product on the EU market bears the due diligence obligation. A supplier's DDS supports but does not replace yours. You must independently assess the evidence and file your own statement.
Does Thailand's low-risk classification reduce my verification obligation?
No. Low-risk reduces competent authority inspection frequency (1% vs 9%), not the obligation. You must verify geolocation, deforestation-free status, legality, and traceability for every consignment from Thailand.
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.
Does a supplier certification reduce my verification burden?
No. Certifications inform your risk assessment but do not replace EUDR due diligence. A certification does not produce a DDS, does not guarantee plot-level geolocation, and does not verify against the December 31, 2020 cutoff.
Rubber supply chains span 3-5 aggregation tiers, each introducing conversion variability and traceability risk the EU importer must verify before filing. 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.