EUDR Declaration in Excess Guidelines
Core Principles
The regulation mandates precise correspondence between marketed commodities and production plots. Exceptions for excess declarations are permitted only under specific circumstances with strict compliance requirements.
Permissible Circumstances
Acceptable Scenarios
Excess declarations are permitted when:
- Handling fully traced bulk commodities
- No mixing with unknown origin materials
- No mixing with non-compliant commodities
- During legitimate logistics or production processes
Common Applications
Applicable during:
- Silo storage
- Ship transportation
- Mill processing
- Partial market placement
Compliance Requirements
Due Diligence Obligations
Operators must demonstrate:
- Risk assessment for all declared plots
- Negligible non-compliance risk
- Full traceability documentation
- Comprehensive risk mitigation
Risk Assessment Focus
Special attention to:
- Product traceability challenges
- Circumvention risks
- Mixing prevention
- Compliance verification
Prohibited Practices
Unacceptable Declarations
The regulation prohibits:
- Regional-scale declarations
- Country-wide declarations
- Excessive plot declarations
- Broad geographic generalizations
Implications
Broad declarations:
- Prevent proper due diligence
- Hinder authority checks
- Violate core obligations
- Risk non-compliance
Legal Responsibilities
Operator Obligations
- Full responsibility for all declared plots
- Complete due diligence requirements
- Risk mitigation to negligible levels
- Compliance documentation
Non-Compliance Implications
- Single plot non-compliance affects entire declaration
- All declared plots must meet standards
- Full risk assessment required
- Comprehensive verification needed
Frequently Asked Questions
Q: When can operators declare additional plots?
A: Only for fully traced bulk commodities not mixed with unknown origin or non-compliant materials.
Q: What responsibilities come with excess declarations?
A: Operators must ensure compliance and conduct full due diligence for all declared plots.
Q: Can operators declare plots on a regional basis?
A: No, broad-scale regional or country-wide declarations are not permitted.
Q: What happens if one declared plot is non-compliant?
A: The entire set of declared plots becomes non-compliant.