Why does one European Union (EU) buyer ask me for plot coordinates and another only for an invoice under the EU Deforestation Regulation (EUDR)?

Often because their role differs. The upstream operator that first places goods on the EU market does due diligence and normally needs plot geolocation (micro and small primary operators can give an address). Downstream operators and traders mainly keep supplier and buyer records for at least 5 years and do not file statements.

Three roles, three workloads

• Upstream operator: places a relevant product on the EU market for the first time, or exports it from the EU. It carries out due diligence, submits a due diligence statement (DDS) and passes the DDS number to its direct downstream buyers.
• Downstream operator: places on the market or exports products that have all already been through upstream due diligence, usually after processing them into another relevant product. The Commission gives an EU company making chocolate from cocoa beans already placed on the market as an example.
• Trader: usually sells already-checked products within the EU without changing the product code.

What downstream buyers must do

• All downstream operators and traders must collect and keep certain information on their suppliers and buyers for at least 5 years, and notify buyers and Competent Authorities if they find a product might not comply.
• They "do not need to carry out due diligence, submit due diligence statements or simplified declarations, or have a due diligence system in place".
• Large ones must also register in the Information System and, only if they learn a product might not comply, verify that upstream due diligence was done and found only negligible risk. Downstream micro, small or medium-sized enterprises (SMEs) do not register or verify.

The first downstream buyer

The first buyer of a product from an upstream operator must also collect the DDS reference number or simplified declaration identifier and keep it for at least 5 years. The Commission says your supplier passes the number on, and you do not need to self-identify or ask for it.

What this means for your data pack

• Our reading: a buyer that imports your goods into the EU is usually the upstream operator, so it needs the full plot-level file from you.
• Our reading: a buyer further down, such as an EU processor or distributor, may ask only for invoices, supplier names and the DDS number that came with the goods. Ask the buyer which role it holds before you build a file for it.

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

Sources: European Commission Green Forum, EUDR roles and responsibilities

Last reviewed 2026-11-05. Roles and duties are from the Commission roles page. The role of a given buyer depends on its own activity, so confirm it with the buyer.