How long do records have to be kept under the European Union (EU) Deforestation Regulation (EUDR), and what must large buyers publish?

The Commission says all due diligence documents must be kept for five years from the date the product is placed on the EU market or exported. Operators must review their due diligence system at least once per year, and large operators must publicly report on it, including online.

Three duties from the Commission page

• Keep: all documents related to due diligence, including procedures, records, updates and the information gathered in step 1, for five years from the date of placing on the market or export.
• Review: the due diligence system must be updated whenever anything important changes, and reviewed at least once per year.
• Publish: large operators, meaning businesses that are not micro, small or medium-sized enterprises, must publicly report on their due diligence system, including online. The page's own wording adds "including microenterprises or natural persons", which reads oddly beside that, so check the legal text for who counts as large.

One reporting route

Operators who must carry out value chain due diligence under other EU legislation can meet their EUDR public reporting by including the information in those existing reports.

Downstream buyers keep records too

Downstream operators and traders keep records too. Our page on buyer roles has the detail.

What it means for you

• Our reading: assume the buyer may ask for a document from a lot years later. Keep land records, plot files, purchase receipts and tax invoices for each lot for at least five years from the date your buyer places the lot on the EU market (later than shipment), in a folder per lot.
• Our reading: when you correct a plot or a quantity, keep the earlier version and note the date, since the Commission says operators should be able to demonstrate how due diligence was carried out.
• Do not rely on the buyer holding your originals.

What Senseible does here

Senseible reads the HS code on each purchase invoice and keeps every invoice dated, so you can show your buyer what came in, from whom and when. Plot coordinates come from your growers and your buyer files the statement. We do not file statements or certify deforestation-free status.

• What an Indian supplier gives the EU importer for the statement
• Does EUDR apply to my Indian exports?
• Geolocation for Indian smallholder farms
• EUDR readiness: what applies to your goods
• Why buyers ask for different forest data

Sources: European Commission Green Forum, Understand due diligence under the EU Deforestation Regulation, European Commission Green Forum, EUDR roles and responsibilities

Last reviewed 2026-11-05. The Commission page words the large operator public report line as quoted; check the legal text for who counts as large. The five years run from placing on the market or export, not from the harvest.