A due-diligence statement is not the entire evidence record. The underlying information still needs to support the product, source, legality, geolocation, risk assessment and supply-chain handoffs behind the statement.
A due-diligence position can depend on product identity, country of production, plot geolocation where required, production context, legality information, deforestation-free support, risk assessment and mitigation records where applicable. Those elements have to remain linked to the relevant product and supply-chain handoff.
product / commodity identity
supplier / operator identity
country of production
plot or geolocation information where required
production date or period where relevant
legality evidence
deforestation-free support
risk-assessment information
mitigation records where applicable
due-diligence statement/reference identifiers
supply-chain handoffs
document versions, corrections and updates
A document can be authentic and still fail to support the claim attached to it. Documentary review therefore tests relationships: product to supplier, supplier to producer, producer to installation, reported value to source record, and current file to the versions that preceded it.
Commission Implementing Regulation (EU) 2026/1565 amended the technical rules for the EUDR Information System, including due-diligence statements, simplified declarations for certain micro and small primary operators and technical interfaces. Reference numbers, corrections and handoffs therefore form part of the documentary record.
Regulatory files are often revisited after the operational work has finished. Preserving what was received, what changed, what was corrected and what was relied upon makes later internal review, professional advice, verification or authority scrutiny easier to reconstruct.
The current application dates are 30 December 2026 for large and medium operators and for micro/small operators already covered by the EU Timber Regulation, and 30 June 2027 for most other micro and small operators. A company should confirm its own role and applicable date.
The statement or reference submitted to the Information System is a regulatory output. The supporting record can be much broader: supplier information, geolocation, legality documents, risk information, mitigation records, reference numbers received from upstream and evidence of corrections or changes. Documentary review asks whether those materials still support the statement being relied upon.
WEETRA examines the documents in scope, the facts asserted by those documents, the relationships between actors and regulated objects, the consistency of quantities and periods, competing versions, contradictions, remediation and what the available records cannot establish.
CBAM is WEETRA’s current primary operational review application. EUDR and DPP are developing regulatory-evidence applications and are not presented as identical commercial services.
Official regulatory sources are used to describe the current legal position. WEETRA commentary explains documentary implications and is not legal advice.