Yes, you may organize the five-year retention obligation under the EUDR yourself. The regulation prescribes no specific system or provider; it prescribes that you keep the underlying documents, geolocation data and the due diligence statement accessible for five years to the competent authority. How you technically arrange this is up to you.
The question that lies behind this in practice is different: can you manage to do this for five years consistently, completely and findably with the resources you currently have? For a single product stream with a stable supplier, that is often feasible. As soon as multiple raw materials, countries or suppliers come into play, the risk grows that something is missing when you need it.
What the retention obligation concretely requires of you
It is not about a single document but about a file: the due diligence statement itself, the geolocation data of the plots, the documents with which you substantiate origin and legality, the risk assessment you have conducted, and the correspondence with suppliers about it. All these components must be retained together for five years and, upon request, be quickly retrievable. Which documents exactly varies per raw material; the emphasis is different for coffee than for timber or cattle. An overview per raw material can be found in the knowledge base with documentation per raw material.
What you can perfectly do yourself
A number of matters are administrative in nature and require no specialist knowledge. You can yourself set up a fixed folder or file structure per product stream, so that geolocation data, invoices and statements are kept together. You can yourself maintain a list of which document belongs to which shipment and when the retention period for that document begins to run. And you can yourself agree who within your organization is responsible when someone is on holiday or leaves. The latter may sound self-evident, but in practice it is the most common reason a file becomes incomplete: the knowledge was held by one person, not in the system.
Where doing it yourself often goes wrong
Most problems do not arise during collection, but in keeping it consistent over time. A spreadsheet or a series of email folders works well the first year, but quickly becomes outdated after a few changes of supplier, employee or product line. Another recurring bottleneck is that geolocation data and the corresponding statement are kept separate from each other, so that at the moment of a request it is not immediately clear which file belongs to which shipment. And because the retention period per document can begin running at a different time, it is difficult to track with a loose folder structure when something is still relevant and when it no longer is.
Doing it yourself, with support where it matters
Many SMEs therefore choose a middle way: the source documents and the supplier relationship remain with them, but the structure, the link between geolocation and statement, and the monitoring of the deadline are supported by a system. This is also where eudri.com fits in: we structure and validate the file per product stream and generate the statement from it, but the legal risk assessment and the final decisions remain with you as the economic operator. Because a file also contains commercially sensitive supplier data, it is worth checking in advance how data is stored and secured; this is explained on the page about how we handle your data.
First understand where you stand
Before you decide how to organize the retention obligation, it is useful to first have a clear picture of what role you have in the supply chain and what obligation goes with it, because that also determines what your file should look like. You can check this in a few questions with the free role check. If you want to see exactly which steps we automate and which remain your responsibility, please see how the process from dossier to declaration works.
For your specific situation, including the question of whether your current record-keeping method is adequate, a legal advisor or the competent supervisory authority remains the right point of contact. If you want to explore first what applies to your products and role, start with the free role check or browse through the topics in the knowledge base.