EUDR record-keeping: five years of records, an annual review, and a public report

Most EUDR attention goes to the per-shipment work. The duties that bite later are the standing ones: what you keep, how often you look at your own system, and what you publish about it.

Five years of records

Operators keep the records of their due diligence for five years (Art. 4(3)), and the first downstream actor in the chain keeps the DDS reference it collected for the same period (Art. 5). In practice this means the case file behind every statement, the evidence behind every conclusion, and the trail of who decided what, all retrievable years after the people involved have changed jobs.

The annual review of the due-diligence system

Article 12(2) requires operators to review their due-diligence system at least once a year and update it when new circumstances warrant it. It is a duty on the system itself, not on any one shipment: do the procedures still match how you actually source, did country benchmarks or guidance change, did concerns surface that the system missed. The review should be recorded, because an unrecorded review is indistinguishable from no review.

The public report for non-SMEs

Operators that are not SMEs must report publicly, at least annually, on their due-diligence system and the steps taken under Article 8 (Art. 12(3)). Article 12(4) sets the content: a summary of the information collected on products, quantities and countries of production, the conclusions of the risk assessments with the mitigation taken and the evidence relied on, and the process of consultation with indigenous peoples and local communities where relevant. Reporting made under other EU due-diligence acts can satisfy the duty if it covers the same ground.

Sylva keeps the five-year record as a working case file rather than an archive: the audit log, the register export and the authority package pull the records out in the shape a competent authority asks for, the annual review is recorded with a date and a note, and the public report drafts itself from the recorded data with the Article 12(4) structure.