What must I keep for five years under the deforestation regulation?

Five years: the due diligence declaration plus the evidence behind it

The five-year retention obligation applies to the due diligence declaration itself, together with all information and documents used to substantiate that declaration. This is therefore not only the form submitted to the EU information system, but the entire supporting file: the geolocation data of the plots where the product originates, data on suppliers and customers in the supply chain, the quantity and description of the product, and the documents proving that production and trade complied with the legislation of the country of origin.

In practice, this involves a variety of material: contracts and invoices, correspondence with suppliers, certificates or permits from the country of origin, and the risk assessment you carried out that led to the declaration. These documents must be retained from the moment the declaration is submitted or the product is placed on the market, so that a competent authority can request them during an inspection. Which documents are precisely relevant depends on the product stream and your role in the supply chain; the key point is that the substantiation of the declaration must remain available for as long as the declaration itself.

Where this is set out: Articles 4 and 9 of the Regulation

This retention period derives from Regulation (EU) 2023/1115: Article 4 sets out the obligations of economic operators regarding the due diligence declaration, and Article 9 lists the information to be gathered in the context of the due diligence obligation, such as geolocation data, supplier information and evidence of compliance with the relevant legislation in the country of production. The full text of both articles is available on EUR-Lex.