As the EU importer filing the Due Diligence Statement, you bear the full legal burden of proof under Article 4. Your supplier may provide geolocation data, deforestation screening reports, and traceability documentation — but the EUDR does not allow you to accept this evidence at face value. This checklist helps you systematically verify what your soy supplier has provided and flag items requiring additional investigation before you file.
What is the EU importer's verification obligation?
Under Regulation 2023/1115, the operator placing a product on the EU market must exercise due diligence — not merely collect evidence, but critically assess it. Article 10 requires evaluation using "adequate and verifiable information." Accepting supplier documentation without independent verification does not constitute due diligence. The competent authority holds the filing operator accountable for evidence quality, not the supplier who provided it. If evidence contains inconsistencies or red flags, the importer must resolve them before filing or decline the consignment.
What this template covers
Supplier documentation review
- Verify the supplier has provided documentation for every farm contributing to the consignment — not a representative sample
- Confirm documentation identifies every supply chain tier: farms, grain elevators, traders, crushers, and exporter
- Check internal consistency — farm names, coordinates, and volumes align across geolocation files, delivery records, and transport documentation
- Verify certifications (ISCC, ProTerra, or equivalent) are cited as supplementary evidence only — certifications do not satisfy the EUDR's due diligence requirement
- Confirm raw evidence files are provided, not just summary reports or attestation letters
Red flags: Supplier provides a single attestation letter with no farm-level documentation. Certifications cited as sole evidence of deforestation-free status. Documentation references "multiple farms" without identifying each one.
Geolocation data verification
- Verify supplier-provided coordinates are field-captured, not estimated, with collection timestamps and device metadata
- Confirm coordinates use WGS84 (EPSG:4326) at 6-decimal precision
- For plots exceeding 4 hectares (most commercial soy farms): verify polygon boundaries, not single GPS points
- Cross-check a sample against satellite imagery to confirm agricultural land, not forest or water
- Verify the number of geolocated plots matches the number of farms claimed
Red flags: Round-number coordinates (e.g., -12.500000, -55.000000) — likely estimated. Multiple plots with identical coordinates — copy-paste. Missing timestamps on geolocation records. Coordinates within protected areas or indigenous territories.
Deforestation-free evidence assessment
- Verify screening uses satellite imagery anchored to the December 31, 2020 baseline
- Confirm the FAO forest definition is applied correctly — Cerrado savanna below FAO thresholds (5m height, 10% canopy, 0.5 ha) is not forest; its conversion is not deforestation under the EUDR
- Verify screening methodology is documented: data sources, imagery provider, resolution, and decision criteria
- Cross-reference against at least one independent alert system (PRODES/DETER for Brazilian origins, Global Forest Watch)
- Confirm the Amazon Soy Moratorium is not cited as satisfying EUDR requirements — it is voluntary, covers only the Amazon biome, and uses a different cutoff date
Red flags: No deforestation alerts for any plot in a high-deforestation region — may indicate inadequate methodology. Imagery resolution too coarse for small-scale clearing. No independent cross-referencing. Indirect land use change indicators in the supply region.
Legality evidence assessment
- Verify the supplier identified relevant legislation: land use laws, environmental protections, labour laws, tax obligations, and indigenous rights including FPIC
- For Brazilian origins: verify CAR (Cadastro Ambiental Rural) registration per farm — active registration, no environmental embargoes
- Cross-check CAR numbers against the public SICAR database to confirm they match coordinates provided
- Verify legal evidence goes beyond self-attestation — permits, licences, or third-party verification on file
- Confirm export authorisations are current for the specific consignment
Processing and traceability verification
- Verify grain elevator intake records link each delivery to a specific farm — elevator-level aggregation alone is insufficient
- Confirm outbound shipments link to contributing source farms, not an undifferentiated pool
- Verify crush yield documentation (~80% meal, ~18% oil) with reconciliation methodology
- Check volume reconciliation: outbound volume should reconcile against inbound within documented tolerance
Red flags: Volume gaps exceeding 5% unexplained. Identity preservation claimed but no lot-level linkage produced. Mass balance language anywhere in documentation — the EUDR prohibits mass balance (Article 9).
Risk assessment and DDS readiness
- Verify the risk assessment covers all Article 10 factors: country classification, deforestation prevalence, supply chain complexity, and circumvention risk
- Confirm the "negligible" conclusion is supported by evidence, not merely asserted
- Verify documented mitigation measures were implemented before shipment where risks were identified
- Confirm evidence is archived for the 5-year retention period (Article 12)
- Assess whether the package would withstand competent authority scrutiny
How to use this template
Step 1 — Request the full evidence package. Ensure your supplier has provided geolocation files, screening reports, legality evidence, processing records, and traceability documentation for every contributing farm. For soy, verify farm-level data survived the grain elevator aggregation step — silo mixing is the point where individual traceability most often disappears.
Step 2 — Work through each section. Mark items verified only when independently confirmed — not when the supplier has asserted it. Focus on red flag items.
Step 3 — Escalate red flags. Any red flag requires additional investigation. Do not file a DDS with unresolved red flags.
Step 4 — Document your verification. Record what you checked and how you resolved issues. Your verification process is itself due diligence evidence.
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 farms, elevator operations, or intermediary chain. For each consignment, verify that farm-level data survived the grain elevator aggregation step — silo mixing is the point where individual farm traceability most often disappears, and this must be confirmed fresh each time.
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 farm-level data, not elevator-level aggregates. Gate customs release on checklist sign-off — no signed-off checklist, no release authorisation. Integrate QC inspection at port with the verification process so that physical quality checks and documentation review happen as a coordinated step rather than separate procedures.
Who needs this template
- EU importers verifying soy supplier evidence packages before filing a DDS
- Compliance officers assessing whether upstream evidence supports a defensible Due Diligence Statement
- Procurement managers evaluating supplier evidence quality for continued sourcing under EUDR
Does completing this checklist mean my DDS will pass?
No. Completing every item means you have systematically reviewed the evidence — it does not certify compliance, guarantee a successful regulatory review, or substitute for independent legal counsel. The competent authority assesses the substance of your evidence, not whether you completed a checklist.
What if my supplier cannot provide farm-level data?
The EUDR requires geolocation to the plot of land where the commodity was produced (Article 9(1)(d)). Elevator-level or regional-level data does not support a defensible DDS. Require farm-level data or decline the consignment.
Is the Amazon Soy Moratorium sufficient for EUDR compliance?
No. The Moratorium is voluntary, covers only the Amazon biome, uses a 2008 cutoff (not the EUDR's December 31, 2020 baseline), and does not produce a DDS. It may inform risk assessment as supplementary context but cannot replace independent screening.
How should I handle soy from the Cerrado biome?
Apply the FAO forest definition precisely. Cerrado vegetation meeting FAO thresholds (5m height, 10% canopy, 0.5 ha area) is forest — its post-2020 conversion is deforestation. Cerrado below these thresholds is not forest. Verify your supplier's screening applies the FAO definition correctly rather than treating all Cerrado conversion as equivalent.
Soy verification demands that EU importers independently assess evidence across grain elevator aggregation, biome-specific deforestation definitions, and multi-tier supply chains. A checklist structures the review — a platform automates the verification. Book a demo to see how ResourceLedger helps EU importers verify supplier evidence with audit-grade traceability from farm plot to port of entry.