EUDR Article 9 information requirements: the complete checklist

Article 9 of Regulation (EU) 2023/1115 sets out the information an operator or trader must hold before placing a relevant product on the EU market or exporting it: a description of the product, its quantity, country and plot-level geolocation, supplier and customer details, and verifiable evidence it is deforestation-free and legally produced. Miss one item and the due diligence statement doesn't just get flagged — it can't be filed at all.

Every sector and how-to guide on this site references Article 9 data in passing, because almost everything else — the due diligence statement, the risk assessment, the record-keeping obligation — is built on top of it. This page sets out the full list once, so you can check your own files against it rather than piecing it together from each commodity guide.

What Article 9 actually asks for

The regulation requires the information to be "adequately conclusive and verifiable" before you can conclude the risk is negligible. In practice, that means the following, for every consignment:

Information required	What it covers	Where it bites
Product description	Trade name, type of product, CN code, and — for wood products — the common name and full scientific name of the species	A CN code that doesn't match current Annex I scope is the single most common reason a filing is rejected
Quantity	Net weight in kilograms, plus the supplementary unit set out in Annex I where one applies to that commodity	Must reconcile with the commercial invoice and transport documents for the same shipment
Country and region of production	The country, and the specific region or district within it, not just "country of origin" on a customs form	Country-level benchmarking does not excuse you from recording where inside that country the commodity actually came from
Geolocation	A single point for plots under 4 hectares, a polygon for plots of 4 hectares or more, or the establishment for cattle	The most common reason a statement can't be filed at all — see the dedicated geolocation guide below
Date or time period of production	When the commodity was actually produced, not when it was shipped or invoiced	Feeds directly into the post-2020 cut-off test
Supplier details	Name, address and contact details of whoever supplied you the product	Required even if you only trade the product and never touch the plot yourself
Customer details	Name, address and contact of your direct customer, where you place the product on the market	Part of the traceability chain the regulation builds downstream, not just upstream
Evidence the product is deforestation-free	Information showing the land was not deforested, and wood not linked to forest degradation, after 31 December 2020	"Adequately conclusive" is a legal standard the regulation sets, not a box you can tick without underlying evidence
Evidence of legal production	Information showing production complied with the applicable laws of the country of production — land use, environmental, labour, tax and trade rules among them	Often the weakest part of a file, because it requires proof from a jurisdiction, not just from a supplier
Risk assessment outcome	The conclusion that risk is negligible, and any mitigation measures applied to reach it	Article 9 data is the input; Articles 10 and 11 are what you do with it

Product description: what "trade name and type" actually means

A generic commodity name is not enough. You need the trade name you actually use commercially, the type of product, and the CN code that places it within the current Annex I scope. For anything containing or made from wood, you also need the common name and the full scientific name of the species — a supplier invoice that says "tropical hardwood" does not meet this requirement on its own. Scope has moved more than once since the regulation entered into force, most recently through the Annex I recast; always check a code against the current list rather than a spreadsheet from last year's filing.

Quantity: net weight, and sometimes a supplementary unit

Quantity is recorded as net weight in kilograms. For some commodities, Annex I also specifies a supplementary unit — for example a count or volume measure alongside the weight — and you need both where one applies. Whatever figure you file has to reconcile with the commercial invoice and the transport documents for that consignment; a mismatch here is a routine reason for a statement to be queried.

Country and region: why "country of production" isn't the whole answer

Article 9 asks for the country of production and, where applicable, the region or district within it. This matters even for commodities from a country benchmarked low risk: the benchmark applies at country level, but your due diligence record still has to show where, specifically, within that country the commodity came from.

Geolocation: the item that stops most filings

Geolocation is where most businesses first discover they don't have what Article 9 requires. For plots under 4 hectares, a single coordinate point will do. For plots of 4 hectares or more, you need a polygon describing the plot's perimeter. For cattle, it's the geolocation of the establishment rather than a plot. Where a product contains or was made using commodities from more than one plot of land, Article 9 requires the geolocation of all of them, not a representative sample — a blended batch of coffee from forty smallholdings means forty sets of coordinates, not one.

EUDR geolocation requirements: polygons, points and the 4-hectare rule covers the precision standard and the common formatting mistakes in full; treat this as the one item on the Article 9 list worth starting on first, because it depends on your suppliers, not on you.

Supplier and customer details: both directions of the chain

You need the name, address and contact details of the business or person who supplied you the product. If you place the product on the market yourself, you also need the same details for your direct customer. This applies whether or not you handle the physical commodity — a trader who never touches a bag of coffee still has to record who they bought it from and who they sold it to.

Evidence of deforestation-free status: what "adequately conclusive" means

The regulation's own cut-off date is 31 December 2020. Article 9 requires information demonstrating the land was not subject to deforestation, and that wood was not linked to forest degradation, after that date. The regulation calls for evidence that is "adequately conclusive and verifiable" — satellite monitoring data, land registry records, or a supplier's own geolocation history consistent with no land-cover change, rather than a supplier's written assurance on its own. A signed form from an upstream supplier is a start, not the finish.

Evidence of legal production: the part people underestimate

Separately from deforestation status, Article 9 requires evidence that production complied with the laws of the country of production — covering land use rights, environmental protection, labour and human rights, tax, anti-corruption, trade and customs rules, and free, prior and informed consent where indigenous peoples' rights are affected. This is the item most often collected thinly, because it asks for proof against a legal system you may not operate in yourself, not just a commercial record from your supplier.

When you have to update this information

Article 9 information isn't a one-off exercise per supplier relationship. It has to be current for the specific consignment you're placing on the market or exporting, and updated whenever the underlying facts change — a new plot enters the supply chain, a supplier changes, or a country's risk classification shifts. EUDR risk assessment and mitigation guidance covers how that ongoing obligation plays out once you've assessed the risk as negligible once and need to keep it that way.

How this becomes a due diligence statement

Article 9 tells you what to collect. The due diligence statement is where you declare it. Once the data above is assembled, filing happens through the EU's TRACES-based Information System — see How to submit a due diligence statement in TRACES, step by step for the submission mechanics themselves, including the two numbers (reference and verification) the system returns once a statement is accepted.

Who actually has to collect it

Every operator placing a relevant product on the EU market, or exporting it, has to hold this information and be able to produce it on request — that obligation did not change with the 2025 amendment. What changed is who files the resulting statement: downstream operators and traders generally no longer submit their own DDS, but non-SME downstream operators and traders still have to register in the Information System and retain the upstream reference number. Do downstream operators and traders still need a due diligence statement? sets out exactly where that line falls. Micro and small primary operators sourcing exclusively from low-risk countries may qualify for the simplified declaration instead of the full statement — see EUDR micro and small operator simplifications: what you actually get — but the underlying Article 9 information is still what the simplified route is built on; it reduces the filing, not the facts you need to hold.

However far along your own compliance work is, the practical order is the same: work out which EUDR deadline applies to your business, then start collecting against this list well ahead of it. Geolocation and legality evidence are the two items that take longest to gather from suppliers who have never been asked for them before.

Check what your business needs to do under the EUDR to get a dated plan built around which of these items you already hold and which you don't.