This checklist provides a 26-point framework for soy operators and traders to assess readiness for the EU Deforestation Regulation. It is organised by supply chain tier — from farm-level sourcing through grain handling, crushing, and export — reflecting the aggregation that occurs at grain elevators and silos where soybeans from multiple farms are combined before processing.
Completing this checklist does not constitute compliance. The EUDR requires operators to exercise due diligence and file a Due Diligence Statement substantiated by evidence. This checklist helps identify where your evidence chain has gaps before a competent authority finds them.
What is the EUDR soy compliance obligation?
Regulation 2023/1115 prohibits placing on or exporting from the EU market commodities that are not deforestation-free or were not legally produced. Soy and its derived products — soybeans (HS 1201), soybean oil (HS 1507), and soybean oilcake and meal (HS 2304) — are among the seven covered commodity groups.
For soy, the supply chain spans 4-5 tiers: farm to grain elevator or silo, elevator to trader, trader to crusher, crusher to exporter, exporter to EU importer. Grain elevators are the critical aggregation point — a single elevator may receive soybeans from dozens or hundreds of farms. The operator filing the DDS — typically the EU importer — bears the full burden of proof under Article 4.
A key distinction for soy: the EUDR uses the FAO forest definition (minimum thresholds for tree height, canopy cover, and land area). Cerrado savanna that does not meet these thresholds is not classified as forest, and its conversion is not deforestation under the EUDR. Operators must apply the FAO definition precisely. The Amazon Soy Moratorium is a voluntary industry agreement covering the Amazon biome only and is not legally binding under the EUDR.
What this template covers
Sourcing and geolocation (Articles 9(1)(d), 9(1)(e))
- All source farms identified and geolocated in WGS84 (EPSG:4326) at 6-decimal precision
- Single GPS point captured for plots of 4 hectares or less; polygon boundaries captured for plots exceeding 4 hectares (note: most commercial soy farms substantially exceed 4 hectares)
- Geolocation data includes collection timestamp, device metadata, and collector identity — not just raw coordinates
- Each plot linked to an identified farmer or landowner with tenure documentation on file
- Planting season and harvest date recorded for each consignment to verify production against the December 31, 2020 deforestation cutoff
- For plots in or near the Cerrado, Amazon, or Chaco biomes: satellite imagery analysis performed to confirm no forest loss (per FAO definition) after December 31, 2020
Risk assessment (Article 10)
- Country risk classification confirmed for each origin (standard, low, or high risk) using current EU benchmarking
- Deforestation screening performed using satellite imagery anchored to the December 31, 2020 baseline
- FAO forest definition applied correctly — tree cover loss in areas not meeting FAO forest thresholds (5m height, 10% canopy cover, 0.5 ha minimum) documented and assessed separately from deforestation
- Independent deforestation alert systems cross-referenced for each source area (e.g., Global Forest Watch, PRODES/DETER for Brazilian origins)
- Risk assessment methodology documented: data sources, resolution, thresholds, and decision criteria recorded
- Where concerns identified: risk mitigation measures documented and implemented before DDS filing (Article 10(2))
Legality verification (Article 9(1)(e))
- Relevant legislation of the country of production identified (land use laws, environmental protections, labour laws, tax obligations, and indigenous rights including FPIC)
- Legal compliance evidence collected or supplier attestation obtained with supporting documentation for each origin
- For Brazilian origins: CAR (Cadastro Ambiental Rural) registration verified — farm boundary registered in the Rural Environmental Registry with no outstanding environmental embargoes
- Applicable permits, environmental licences, or export authorisations on file and verified as current
Processing and traceability (Articles 4, 9)
- Grain elevator and silo intake documented — each delivery linked to the specific farm of origin
- Elevator-level traceability established — each outbound shipment linked to the specific set of contributing source farms
- Crush yield documented where applicable (approximately 80% meal and 18% oil from whole soybeans) with measurement methodology
- Processor intake reconciled against outbound volumes of meal, oil, and derivative products within documented tolerance
- Batch or lot identifiers maintained from farm through elevator, crusher, and exporter with traceability links at each transfer
- No mass balance applied — the EUDR prohibits mass balance; physical segregation or identity preservation required
Documentation and filing (Articles 4, 9, 12)
- DDS prepared with all required fields under Article 4(2) before the product is placed on the EU market
- All supporting evidence archived and retrievable for the mandatory 5-year retention period (Article 12)
- Evidence chain auditable end-to-end: competent authority can trace from filed DDS to individual farm through each aggregation stage
- DDS reference number obtained from the EU Information System and linked to shipment and customs documentation
How to use this template
Step 1 — Map your supply chain. Document every tier from source farm to EU market entry: farms, grain elevators, traders, crushers, exporters, and the EU importer. For soy, identify grain elevator aggregation points first — this is where individual farm traceability is most frequently lost.
Step 2 — Work through each section. Mark items complete only when documentary evidence exists — not when a process is planned or verbally confirmed.
Step 3 — Close gaps before filing. Prioritise farm-level geolocation and elevator traceability, as grain aggregation is the hardest gap to close retroactively.
Step 4 — Review quarterly. New supplying farms, elevator sourcing changes, and risk reclassifications require reassessment.
How to implement this in your organisation
Assign ownership. Your compliance officer or sustainability manager owns this checklist and is accountable for its completeness. Procurement staff and grain elevator operators contribute sourcing evidence; the export manager reviews the assembled package before DDS filing.
Set the review cadence. Link deforestation screening reviews to planting cycles — September through December for Brazilian origins and April through May for Argentine origins — so screening is current before each harvest enters the supply chain. Conduct a full checklist reassessment quarterly and immediately when triggered by a new supplying farm, a new elevator sourcing arrangement, or a country risk reclassification by the European Commission.
Define your escalation path. Any gap identified during review halts DDS preparation for the affected consignment until the gap is closed. The responsible team member escalates unresolved gaps to the export manager within 48 hours, with a documented explanation of the gap and a proposed remediation timeline.
Connect to existing workflows. Integrate farm-level geolocation capture into your supplier onboarding process so plot data is collected before the first delivery to the elevator. Link CAR verification and elevator traceability checks to your existing procurement and QC handover points, and attach completed checklist evidence to export documentation packages alongside commercial invoices and phytosanitary certificates.
Who needs this template
- Soy exporters assembling DDS evidence packages for EU-bound consignments
- Crushers and processors documenting yield conversion, batch traceability, and intake reconciliation
- Compliance officers auditing evidence chains across multi-tier soy supply chains before DDS filing
- EU importers verifying upstream evidence meets the standard for a defensible Due Diligence Statement
FAQ
Does the EUDR cover Cerrado vegetation conversion as deforestation?
The EUDR uses the FAO forest definition: land over 0.5 hectares with trees over 5 metres and canopy cover over 10%. Cerrado vegetation meeting this definition is forest; its conversion constitutes deforestation. Cerrado grassland or savanna below these thresholds is not forest, and its conversion is not deforestation under the EUDR. Operators must apply the FAO definition precisely to each source plot.
Does the Amazon Soy Moratorium satisfy EUDR requirements?
No. The Soy Moratorium is voluntary, covers only the Amazon biome, does not use the December 31, 2020 cutoff, and does not produce a DDS. It may inform your risk assessment but cannot replace EUDR due diligence.
How do I handle grain aggregation at elevators?
Each farm contributing soybeans must be individually geolocated and linked to the outbound shipment. Traceability to elevator level alone is insufficient — the EUDR requires traceability to the plot of land where the commodity was produced (Article 9(1)(d)). Physical segregation or identity preservation must be maintained through the elevator.
Does completing this checklist mean I am EUDR compliant?
No. This checklist helps identify evidence gaps. Completing every item means you have documented your evidence chain — it does not certify compliance, guarantee a successful regulatory review, or substitute for independent legal counsel. Operators must exercise due diligence and substantiate their DDS with evidence a competent authority can verify.
Soy supply chains involve large-scale grain aggregation, biome-specific deforestation definitions, and complex elevator-to-farm traceability challenges that distinguish them from other EUDR-covered commodities. A checklist identifies gaps — a platform closes them. Book a demo to see how ResourceLedger provides evidence-grade traceability from farm plot to EU port of entry.