For an EUDR declaration on soya, you must in any case have geolocation data of the production plots, documents that substantiate lawful production in the country of origin, transport and trade documents that link a consignment to those plots, and your own risk assessment together with the measures associated with it. What specifically applies to soya is that this commodity is traded in bulk in virtually all cases: consignments from different plots and sometimes different regions are mixed in silos, inland waterway vessels or ocean-going vessels before they arrive with you.
That mixing does not mean the traceability obligation lapses, but it does mean the file requires an extra layer. Whereas a consignment of coffee beans from a single cooperative can often be managed with a limited number of plots, bulk soya requires the documentation to show which plots a loaded consignment is composed of, even if those plots are already mixed during loading.
What documents the file contains in essence
The core of an EUDR file for soya does not materially differ from that for other commodities. You need data on the supplier, including name, address and country of production. You also need to have the geolocation data of the plots where the soya was grown, as a point for smaller plots or as a polygon for larger ones. Furthermore, there must be supporting documents for lawful production, such as ownership or lease certificates and licences applicable in the country of origin, plus information on the production or harvest period. Finally, there must be trade and transport documents that track the consignment from plot to arrival in the EU, and, if earlier actors in the chain have already submitted a due diligence declaration, the associated reference number.
Anyone building this for the first time will quickly notice that gathering these documents takes more time than filling in a form. established by commodity which documents are involved provides an overview that helps you see what differs for soya compared to, for example, cocoa or timber.
Why bulk processing of soya requires an extra step
The issue where soya importers most frequently encounter problems is that the chain between grower and EU importer is usually longer and more branched than with other commodities in the regulation. A grower supplies to a local storage facility, which supplies to a crusher or exporter, which in turn supplies to a trader who assembles the consignment for shipment. Mixing can occur at any of these points, with soya from multiple plots ending up in the same silo or hold.
What that means for your records
For your file, this means that a geolocation reference to a single plot is often insufficient. A consignment that arrives with you may be composed of multiple plots at the same time, and the regulation also requires that complete set of plots, not a representative sample. Suppliers that operate a mass balance system usually record which plots are included in a loaded consignment and in what proportions; this record belongs in the soya file just as much as the geolocation data itself. If you do not request this record, there is a risk that a file may appear complete, but upon inspection proves not to be traceable to the actual plots of origin.
Whether a supplier has this in order is not always clear from a single conversation. It helps to be clear beforehand about what role you yourself play in the chain, because the depth of the question to your supplier depends on that. see in a few questions what role and obligation applies to you provides a first direction for that, before you enter into the conversation with your supplier.
What if the documents are not complete
It is possible that a supplier provides geolocation data but not the underlying mass balance, or vice versa. In that case, a link is missing that is needed to trace the batch conclusively. What consequences this has for your specific situation and for the submission deadline cannot be answered in general terms; it depends on your role, your product, and the status of your file, and for that consultation with a legal adviser or the competent supervisory authority is the appropriate course.
What can be said in general terms is this: the earlier in the supply chain the link between plots and batches is established, the less reconstruction work is needed later. A file that is built up per product stream, with suppliers, countries of origin and plots clearly organized together, makes that reconstruction work considerably more manageable. how such a file is put together step by step shows which steps are involved, from structuring data to generating the declaration.
Would you like to see first where you stand exactly before asking suppliers for additional documents? The free role check provides an indication of your role and obligations in a few questions, and what a complete file per product stream costs shows what is involved if you need to go deeper.