A container finds out at the border. The work that prevents that happens before it moves.
This page is written for the company bringing goods into the European Union. It sets out which actor normally carries which duty under the EU Deforestation Regulation, what a shared AnyDPP passport puts in front of you for each consignment, and, just as plainly, what it does not do. Coverage language throughout, because the legal conclusion is always the operator's own.
What the importer-side demonstration tests
Your supplier holds the evidence and you answer for it. This is how the two are connected without moving the documents.
This film: AI-assisted production, human-verified content. Synthetic voiceover in English, captions in five languages. Accessibility and AI transparency
Transcript
Your supplier holds the evidence.
You are the one who has to answer for it.
The invoice, the land registry record, the certificates.
They exist, they sit in your supplier's files, and they were never yours to hold.
So the question you have to answer is about facts you have never been able to see.
AnyDPP connects the two sides without moving the documents.
Your supplier's files stay with your supplier.
What reaches you is the structured fact and how well the evidence supports it, and nothing else.
No source document, no commercial value, no storage handle.
Where something is missing, you can ask for it, and the ask goes to the party who can actually answer.
Asking never marks a gap as covered.
Coverage moves only when the evidence does.
A gap you can see is a gap you can still close before the container moves.
Brazil is currently classified standard risk.
Standard risk is not a shortcut.
The normal due diligence requirements still apply.
The question is not the label on the country.
It is the evidence behind your consignment.
A standard-risk country holds exporters who document everything, and a low-risk one holds some who document nothing.
The duty stays with you.
AnyDPP gives you something to stand it on.
Who does what
Three parties, three different jobs. What follows explains which actor normally carries which duty. It does not tell you what your own legal status is: that is settled consignment by consignment, by the arrangement behind each one.
The importer, generally the operator
For goods produced outside the EU, the person acting as importer at release for free circulation is generally the EUDR (EU Deforestation Regulation) operator. Specific arrangements can change which actors carry duties.
Where that is your position, the regulatory work is yours and nobody performs it for you:
- collect the Article 9 information for the consignment, including the geolocation of every plot of land;
- verify and analyse what you collected;
- carry out the Article 10 risk assessment yourself;
- mitigate under Article 11 wherever the risk is not negligible;
- conclude, on your own reading, that the risk is negligible;
- submit the due diligence statement before the goods are placed on the Union market;
- keep the due diligence documentation for at least five years;
- answer the competent authorities when they check, and act on new information or a substantiated concern.
Those checks are planned rather than hypothetical. For goods produced in a country classified as standard risk, each Member State covers at least 3 percent of operators a year, and a check normally arrives without prior warning.
Where the duty is not met, the penalties Member States have to provide include a fine whose maximum, for a company, is at least 4 percent of total annual Union-wide turnover in the preceding financial year, confiscation of the products and of the revenues from them, temporary exclusion of up to 12 months from public procurement and public funding, and a temporary prohibition on placing the products on the market. That is the one place on this page where the number matters, and it is cited rather than dramatised.
Source: Regulation (EU) 2023/1115, Article 2, point (15) (operator, as replaced by Regulation (EU) 2025/2650), Article 4(1) and Article 7; the customs procedure 'release for free circulation' is the one Article 26(1) names. INTERPRETIVE BASIS, recorded because it is not article text: the release-for-free-circulation formulation for identifying the operator comes from the Commission's EUDR guidance and FAQ, not from the Regulation, which is why the published sentence says 'generally' and adds that specific arrangements can change which actors carry duties (primary source) · checked on 25 August 2026
Source: Regulation (EU) 2023/1115, Article 9(1), points (a) to (h); point (b) as replaced by Regulation (EU) 2025/2650, Article 1, point (8)(a); Article 4(2) and Article 33 for the due diligence statement (primary source) · checked on 23 August 2026
Source: Regulation (EU) 2023/1115, Article 10(1) and (4) and Article 11(1) and (3); the due diligence system, its annual review and its record keeping are Article 12 (primary source) · checked on 25 August 2026
Source: Regulation (EU) 2023/1115, Article 12(5) for all documentation related to due diligence, at least five years; Article 9(1) for the Article 9 information, five years from the placing on the market or export; Article 4(3), second sentence, as replaced by Regulation (EU) 2025/2650, for the record of the due diligence statement (primary source) · checked on 6 September 2026
Source: Regulation (EU) 2023/1115, Article 14 (designation), Article 16(1) and (8) to (10) (the 3 percent standard-risk share is Article 16(8); 9 percent high risk is (9) and 1 percent low risk is (10)), Article 16(13) (no prior warning) and Article 18(1) (what a check on an operator examines), each as amended by Regulation (EU) 2025/2650; Article 26 for the customs controls (primary source) · checked on 6 September 2026
Source: Regulation (EU) 2023/1115, Article 25(2), points (a) to (e), point (a) as replaced by Regulation (EU) 2025/2650 (primary source) · checked on 25 August 2026
The exporter in Brazil
The upstream supplier provides the product and production evidence required by its buyer. The EUDR (EU Deforestation Regulation) legal role of each party depends on the specific market-entry arrangement.
In the corridor this site was built for, that means the NF-e (Brazilian electronic invoice) for the lot, the CAR (Rural Environmental Registry (Brazil)) polygon for the property, the MAPA (Brazilian Ministry of Agriculture) certificate, the geolocation of the plots, the production date or period, and the legality documentation behind them. Day to day, the exporter's obligation here runs toward its buyer, under their contract.
Exporting from Brazil does not by itself move the European importer's operator duties onto the exporter. Nor does it follow that a supplier outside the Union can never carry a duty of its own: where the seller is established outside the Union, the first person established in the Union who makes the product available is deemed to be the operator. Who carries what depends on how the goods reach the market.
Source: Regulation (EU) 2023/1115, Article 7 (primary source) · checked on 25 August 2026
Source: Regulation (EU) 2023/1115, Article 4(7), as inserted by Regulation (EU) 2025/2650 (which also deleted the former Article 4(8) to (10)); Article 5, as replaced by the same act, in particular Article 5(3) and (4) for SME traders and Article 5(6) for the non-SME verification duty (primary source) · checked on 6 September 2026
AnyDPP
AnyDPP verifies attributes deterministically against the source documents, assigns a confidence level to each attribute, routes low confidence to a named registered human attester, issues a signed passport whose signature anyone can check against the published issuer key, and shows you the structured regulatory facts together with the evidence support behind each one.
And, explicitly, it does not:
- determine any party's legal role;
- perform your Article 10 risk assessment;
- submit the due diligence statement;
- act as an authorised representative;
- assume your legal duty;
- issue a verdict about a shipment or a company;
- perform satellite deforestation screening, which remains outside this product, within your own risk-assessment tooling or process;
- show prices or commercial terms;
- reveal passports, exporters or consignments that have not been shared with you;
- let anyone mark missing evidence as present by hand.
Source: Regulation (EU) 2023/1115, Article 6(1), as replaced by Regulation (EU) 2025/2650 (primary source) · checked on 25 August 2026
Where evidence gaps still create operational work
The obligation is a documentation obligation. You have to be able to show, per consignment, what you knew, where it came from, and why you considered it sufficient. Not in principle: in a file, on the day somebody asks.
The expensive part is not collecting documents. It is that a document tells you what someone entered, and an audit file needs to say how you knew it was true. Those are different questions, and most supply chains only answer the first.
This page uses coverage language throughout, and no page on this site will tell you that anything settles that verdict for you. It is a legal conclusion about your operation, drawn by your own advisors, and a vendor who claims it is selling you a sentence you cannot use.
How coverage works
Coverage is read for one consignment at a time, against the same evidence item set the public EUDR (EU Deforestation Regulation) evidence map already uses. Each item comes back in one of three states: covered at a confidence level, covered but weak, or missing.
Beside the state sits the class of the backing document, when the item was last verified, and by which route. The class, not the document: the source document itself stays with the exporter.
The separation is the part that matters. Where the passport carries a regulatory fact, you get the value itself and not a badge saying a value exists somewhere: the coordinates of each plot, the quantity in its regulatory unit, the country of production, the production date or period, the product description, the identity of your direct supplier for that consignment. Beside each value sits the evidence support for that value. A badge saying geolocation is covered is no use to an operator that needs the coordinates.
What the view never carries: the source documents themselves, prices or commercial terms of any kind, and anything at all about exporters, consignments or passports that have not been shared with you.
Coverage is an evidence-intake instrument. It is not a regulatory verdict screen, it is not permission to bring goods in, and it is not a completed due diligence process.
Coverage moves when the passport moves, and at no other time.
The request loop
Where an item is missing or weak you can ask the exporter for it from inside the same view, naming the evidence item rather than describing it in an email. The request lands inside the exporter's own workspace.
Nothing about it can be ticked off. There is no control anywhere that turns missing evidence into present evidence: what you see moves only when the underlying passport changes through the normal evidence and verification path.
Where a supplier is not on AnyDPP yet, an invitation goes out from you, naming the evidence categories you are asking for. It brings that supplier in through a commercial relationship it already has, and it grants nothing by itself: the exporter still has to build the passport and share it with you explicitly.
What checking the credential adds
Every attribute in an AnyDPP passport carries the source document it came from and a confidence level. Where the evidence cannot settle it, the design routes the attribute to a registered human attester, whose name would be on that decision.
The check runs against the credential itself, not against a page of ours: the signature is tested against the issuer key published in the issuer's public identifier document, without access to AnyLAI's database. Resolving that key is still a request to the issuer's domain, and today the check follows the procedure AnyLAI documents rather than a generic standards-based tool; both limits are stated on the passport page.
That is the difference worth paying attention to. An audit file assembled from a vendor's dashboard depends on the vendor. An audit file assembled from signed credentials depends on the credentials and on the published issuer key, and a verifier can archive that key.
Test it before you believe any of this
There is a live demonstration passport for a Brazilian coffee lot, published, with its confidence levels and its audit trail visible to anyone holding the link. It carries demonstration content, not a real shipment: the credential, the signature and the verification path are genuine, and the coffee lot in it is demonstration data.
Open it. Follow the verification steps in the public documentation. Take the result to whoever owns your due diligence file and ask them whether it would help.
Less future headache
Four statements, each written to hold under a hostile reading.
- Build the evidence trail before an authority or a buyer has to ask for it.
- When the records are processed before shipment, an inconsistency between the NF-e (Brazilian electronic invoice), the CAR (Rural Environmental Registry (Brazil)) and the phytosanitary certificate can surface before the cargo moves, instead of at the port.
- An evidence trail you open, rather than one you assemble under pressure.
- Signed, and checkable against the published issuer key rather than against AnyLAI's word.
AnyDPP shows which structured facts and evidence signals are present in the passport; you remain responsible for obtaining and retaining whatever information, documents and records your own due diligence requires.
Coverage does not substitute for possession of the records you are legally required to hold, and a passport anyone can verify does not by itself complete due diligence.
Delegation transfers actions, not identity.
The duty of due diligence stays with the operator, and the legal decision is always the operator's.
Source: Regulation (EU) 2023/1115, Article 2, point (15) (operator, as replaced by Regulation (EU) 2025/2650), Article 4(1) and Article 7; the customs procedure 'release for free circulation' is the one Article 26(1) names. INTERPRETIVE BASIS, recorded because it is not article text: the release-for-free-circulation formulation for identifying the operator comes from the Commission's EUDR guidance and FAQ, not from the Regulation, which is why the published sentence says 'generally' and adds that specific arrangements can change which actors carry duties (primary source) · checked on 25 August 2026
The regulatory radar, once a month
What actually changed in EU deforestation and product-passport rules, with a source for each item and nothing else in the envelope.
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Start with the passport, not with us
Everything on this page is checkable in about ten minutes, without talking to a single person. Evaluate the passport on a demonstration consignment and judge the method by what it produces.