The Article 9 list
- Product: description, trade name and type, for example green Arabica coffee or fermented, dried cocoa beans.
- Quantity: in kilograms of net mass.
- Country of production: and the region, where relevant.
- Geolocation of all plots: a point up to 4 hectares and a polygon above that, with at least 6 decimals, plus the harvest date or period.
- Who sold it: name, postal address and email of the business or person supplying the product.
- Who it is sold to: name, postal address and email of the buyer.
- Deforestation-free: adequately conclusive and verifiable information that the plots were not deforested after 31 December 2020.
- Legality: adequately conclusive and verifiable information that it was produced under the country's laws, including the right to use the land.
What counts as "legality"
The regulation defines the laws of the country of production that must be respected on the plot:
- Land use rights.
- Environmental protection.
- Forest rules, where timber is harvested.
- Third-party rights.
- Labour rights.
- Human rights protected under international law.
- Free, prior and informed consent.
- Tax, anti-corruption, trade and customs rules.
In practice, the first document buyers ask for is proof of tenure or the right to use the land for each plot.
How you assess it
With that data you assess the risk. Among other criteria you look at the country's classification, whether there is forest or indigenous peoples in the area, how reliable the information is and how complex the supply chain is, including the risk of mixing in product of unknown origin. Peru is standard risk, so the assessment is a full one.
You also have to keep all that documentation for at least five years. If the authority asks for it, you will go back to your supplier.
A template to organise your suppliers' plot data
Download the template, send it to your suppliers to fill in with one row per plot, and turn it into GeoJSON. The columns use the names the EU system understands.
Before the GeoJSON goes into TRACES, check it for free with the EUDR GeoJSON validator.
How Origen helps
How you file your statement: the EUDR due diligence statement (DDS) in TRACES.
FAQ
Does the supplier have to provide all this even though it does not file the statement?
Yes. The supplier does not file the statement, but without the geolocation of its plots and the origin evidence you cannot file yours.
Is a sustainability certificate enough?
No. Certifications help gather information, but they do not replace the operator's due diligence or the geolocation of every plot.
How long must this data be kept?
The operator must keep its due diligence documentation for at least five years.
What if a plot has no tenure documents?
It is a risk you have to assess and mitigate. It is best to keep that plot out of the shipment until the documentation exists.
Official sources
Regulation (EU) 2023/1115: Articles 2, 9, 10 and 12 (EUR-Lex) Regulation (EU) 2025/2650: the 2025 amendments (EUR-Lex) Implementing Regulation (EU) 2025/1093: country risk classification (EUR-Lex)Informational summary, not legal advice. Always check the official sources before making decisions.