Vendor Due Diligence Checklist for West African Exporters

What EUDR actually requires

The EU Deforestation Regulation (EUDR) covers seven commodities and everything made from them: cattle, cocoa, coffee, oil palm, rubber, soya and wood.^[1] If your buyer sells any of these into the EU, they need a Due Diligence Statement (DDS) tied to your shipment before it can enter customs.

A DDS has to establish three separate things: that the land wasn't deforested or degraded after 31 December 2020, that the commodity was produced legally, and the geolocation of every plot it came from.^[3] None of these can be waved through with a general certificate — the geolocation and deforestation-cutoff requirements are new obligations layered on top of whatever licensing or phytosanitary paperwork you already handle.

Regulation (EU) 2025/2650, adopted in December 2025, pushed the application date back to 30 December 2026 for large and medium operators, and 30 June 2027 for micro and small operators.^[2] That extra runway matters for planning: smallholder cooperatives, which are usually the slowest part of a supply chain to document, now have until mid-2027 if they qualify as micro or small operators.

The DDS itself isn't filed by you. It's lodged by the EU-based importer through the EU's TRACES NT / Information System, referencing your specific consignment.^[6] Your job as the exporter is to hand that importer a complete, verifiable file — this checklist is what that file needs to contain.

The vendor due diligence checklist

• Commodity match. Confirm your product falls under one of the seven covered commodities or their derivatives.^[1] Cocoa butter, cocoa powder, and chocolate products all count, not just raw beans.
• Deforestation cutoff evidence. Be ready to show the land producing your commodity had no deforestation or forest degradation after 31 December 2020.^[3] Land records, satellite history, or cooperative attestations are the usual proof points.
• Legality proof. Assemble whatever domestic licensing shows the commodity was produced legally, including a valid COCOBOD cocoa export licence where cocoa is involved.
• Geolocation data for every plot. This is the newest and most labour-intensive item — see the note on plot-size thresholds below.
• Chain-of-custody trail from farm to shipment. Buyers increasingly want more than a scanned certificate; see what a buyer needs beyond an emailed certificate.
• Timber-specific checks. If wood or wood derivatives are involved, confirm supplier FLEGT status before importing.

On geolocation specifically: evidence requires a single GPS point for plots under 4 hectares, and a full polygon survey for anything larger.^[4] This threshold isn't tied to a published EU source in the material we've verified, so treat it as guidance to confirm directly with your buyer or the relevant authority rather than a citable rule — but it's the operational split you'll be asked to work against, and it resurfaces below in the worked example and comparison table.

What Ghana's risk category changes in practice

The EU sorts countries into low, standard, and high deforestation-risk categories, and the category sets how often shipments get checked at the border. Ghana currently sits in the standard-risk category.^[5] This benchmarking detail also isn't tied to a citable public source in our records, so confirm the current category with your buyer or trade association before you rely on it — categories can be revised.

What standard risk means in practice: your shipments won't get the lightest inspection rate reserved for low-risk countries, but you also don't face the heaviest scrutiny applied to high-risk countries. In workload terms, that usually means your file needs to be complete and internally consistent — dates, plot coordinates, and licence numbers all matching across documents — because standard-risk consignments get pulled for verification more often than low-risk ones, and a mismatched file is the most common reason a shipment gets held up rather than waved through.

Worked example: a cocoa cooperative's shipment file

A cooperative in Ghana's Ashanti region supplies cocoa beans to an EU chocolate importer. Before the importer can lodge a DDS through TRACES NT^[6], the cooperative has to hand over a file covering every step from farm to port.

The cooperative's export manager starts with the paperwork that already exists: a current COCOBOD cocoa export licence and shipment records. The genuinely new work is geolocation. The cooperative sources beans from several hundred smallholder plots, most of them small family farms. Under the 4-hectare threshold noted above^[4], most of these plots only need a single GPS pin, which a field agent can capture in a short visit. But a handful of larger member farms cross the 4-hectare line and need a full polygon survey — a slower, more technical job that typically requires a trained surveyor rather than a phone app.

The real snag isn't the survey itself — it's land tenancy. Several smallholders farm land under informal family or customary arrangements with no title document to point to. Without some form of tenancy or usage record, the cooperative can't credibly attest to the deforestation-cutoff status of that plot^[3], and a plot with no attestation is a plot the importer's DDS can't safely cover. The practical fix cooperatives use is a written attestation from a local chief or land committee, backed by the GPS or polygon data, standing in for a formal title where none exists.

Once every plot has geolocation data and an attestation, the export manager compiles the file — licence, attestation, geolocation, chain-of-custody records — and passes it to the EU importer, who references the consignment when filing the DDS. Because Ghana sits in the standard-risk category^[5], the cooperative keeps a second copy of the full file on hand for the likely event that the shipment is pulled for a border check.

Comparison: what changes by plot size