Methodology and Fact-Checking: How EUDR Guide Verifies Every Fact

Where two sources disagree, the higher wins.

The rules below cover the source order, the four-step check, the labels and the recheck triggers. They apply to every page on the EU Deforestation Regulation (EUDR), including this one, checked on 24 October 2026.

Which Primary Sources Does EUDR Guide Check EUDR Facts Against?

Facts are checked against seven source types in this order of legal weight, and a lower source never overrides a higher one.

This guide's order of sources; a lower row never overrides a higher one.

EU Law: Regulation (EU) 2023/1115 and Its Amending and Implementing Acts

The legal basis of every page is Regulation (EU) 2023/1115 (OJ L 150, 9.6.2023, p. 206), read as amended by Regulation (EU) 2024/3234 (in force 26 December 2024), Regulation (EU) 2025/2650 (in force 26 December 2025) and Delegated Regulation (EU) 2026/2102 (in force 18 September 2026). Every article is explained under Regulation (EU) 2023/1115.

Commission Guidance and the EUDR FAQ

The Commission's interpretation comes from Guidance C/2026/3896 (third edition, Official Journal of 20 July 2026) and FAQ Version 5 (April 2026), cited by section or question number. Article 15(5) of Regulation (EU) 2023/1115, inserted by Regulation (EU) 2025/2650, lets the Commission issue such guidelines. Answers that cite them are in the EUDR FAQ.

National Gazettes and EUDR Competent Authorities

National rules on penalties and authorities are taken only from national gazettes, parliamentary papers and authority pages, each dated. As of 24 October 2026 the Netherlands has an adopted law (Stb. 2024, 242) whose entry into force is open, while Germany has only a government bill (BT-Drs. 21/8278 of 30 September 2026). Authorities are listed under EUDR competent authorities.

FAO Data, Certification Schemes and Secondary Sources

FAO data enter the guide only where an EU act relies on them, such as the Global Forest Resources Assessment behind the Implementing Regulation (EU) 2025/1093 country list (recital 4).

Certification is complementary information under Article 10(2)(n) of Regulation (EU) 2023/1115, and no EUDR certificate exists (FAQ 5.7). What schemes prove is set out under certification and the EUDR. Press, associations and providers serve only as leads or attributed positions.

How Is Each EUDR Fact Checked Before Publication?

This guide checks each fact in four steps of its own routine, not an official standard.

1. Find the provision that states the fact.
2. Read it in the current text.
3. Record instrument, provision and check date.
4. Read the value a second time against the source before publication.

How Does EUDR Guide Separate Binding Law From Non-Binding Guidance?

Only the Regulation and its amending, implementing and delegated acts bind; the Guidance and the FAQ are the Commission's non-binding view, and pages say so whenever a rule rests on them alone. Guidance C/2026/3896 does not amend the Regulation. The FAQ calls itself "a working document drafted by the Commission services" and "not legally binding".

What Happens When Two Official Sources Disagree?

The legal text wins over guidance, and a newer official source wins over an older one; the page uses the article wording and notes the discrepancy. Three cases show the rule:

• Guidance C/2026/3896, section 4(c), cites Article 9(1)(h) for the postal-address alternative, while Article 4a(5) refers to Article 9(1), point (d); pages cite Article 4a(5).
• A footnote of Delegated Regulation (EU) 2026/2102 gives page 35 for the Regulation; it starts on page 206.
• FAQ Version 5 (April 2026), 2.7, 2.8.1, 2.13 and 2.14, still call the Annex I delegated act a draft; it has applied since 18 September 2026.

The Commission's EUDR page summarises the deferral as "Micro and small operators: 30 June 2027"; this guide writes Article 38(3), which also covers natural persons.

How Are Proposals, Delays and Superseded Dates Labelled?

A proposal is always marked "proposed" with its stage and date, and a date that no longer applies appears only as dated history. Each postponement is dated under EUDR delay.

Labels used on every page.

How Are Provisions, Names and Figures Written?

Pages cite the exact provision ("Article 2(28)", "Annex I, note (5)") and use the names and wording of the instrument, not common usage. The system is the "EUDR Information System" (Article 33), and the maximum fine for legal persons must be at least 4 % of total annual Union-wide turnover (Article 25(2)(a)). Costs appear only as dated official estimates, such as COM(2026) 191 of 4 May 2026.

What Is Left Out Until It Is Verified?

A claim that cannot be traced to a primary source is not published, not even as "reportedly"; where a national status was not checked, the page says "not checked" with the date.

When Are EUDR Pages Rechecked and Updated?

Each page shows the date it was last checked and is rechecked when one of five events occurs:

• an amendment of Regulation (EU) 2023/1115;
• a review of the country list in Implementing Regulation (EU) 2025/1093;
• a new edition of the Commission guidance or a new FAQ version;
• a change in national law or authorities;
• a release of the EUDR Information System.

The first country-list review is envisaged for 2026 (strategic framework C/2024/6604, annex), and no act amending or replacing Implementing Regulation (EU) 2025/1093 exists as of 24 October 2026.

How Does Fact-Checking Connect to Independence, Corrections and Legal Advice?

Checked facts are one part of trust; who publishes the guide, how errors are corrected and what the guide is not complete it. Together they make this an independent guide to the EU Deforestation Regulation.

Who Writes and Publishes EUDR Guide?

EUDR Guide is published under the byline EUDR Guide Editorial Team and is not affiliated with the European Commission, any competent authority or any certification scheme. See about EUDR Guide.

How Are Corrections Made?

Corrections are dated on the page they change. See the editorial policy on corrections.

How Can Readers Contact EUDR Guide About an Error?

Errors and outdated values can be reported to editorial@eudrguide.com, ideally with the provision or source concerned. Other enquiries: contact EUDR Guide.

Is EUDR Guide Legal Advice?

No: this guide describes the rules in general, and only the Court of Justice gives the final interpretation of the Regulation.

This guide explains the rules; it is not legal advice for an individual case.