EUDR: What the Deforestation Regulation Requires of Your Supply Chain

What the EUDR regulates

The regulation aims to prevent products associated with deforestation or forest degradation from entering the European market. It applies to a specific set of raw materials and their derived products: cattle, palm oil, soy, cocoa, coffee, natural rubber, and wood from those supply chains.

For these categories, you must collect information on origin, legality, and geolocation, assess the risks, and, depending on your role, submit a due diligence statement to the European information system.

The unique aspect of this regulation is that the burden of proof lies with the supply chain and that the evidence is geographical. Not a statement that everything is in order, but coordinates of the plot where the raw material originated.

When the obligations take effect

The core obligations apply to large and medium-sized enterprises from December 30, 2026. For micro and small enterprises, this is moved to June 30, 2027. These dates are the result of two rounds of postponement, the last of which was regulated in Regulation (EU) 2025/2650.

This postponement was for a practical reason: the information system in which the statements are submitted was not ready. In terms of content, nothing has been relaxed regarding what you must be able to demonstrate.

Therefore, do not view the postponement as a gain. The challenge lies in the supply chain data that you must retrieve from your suppliers. This takes more time than the remaining months suggest.

Are you an operator or a trader?

An operator places a product on the EU market for the first time or exports it from the EU. That party performs full due diligence and submits the statement. A trader resells products that are already on the market and has lighter obligations, depending on the size of the company.

Do you produce within the EU using raw materials covered by the regulation? Are you the first to place the finished product on the market? Then you are an operator with full obligations. This surprises manufacturers who see themselves as processors.

Determine this role first, as it dictates whether you must collect and submit coordinates or whether you primarily need to pass them on and archive them.

Traceability down to the plot

The regulation requires geolocation data of the plots where the raw material was produced or harvested. You link your batches to those plots and record the supply chain steps, from farmer via processor and trader to the factory and ultimately the market.

This is a data issue, not a documentation issue. A supplier who sends a statement but cannot provide coordinates does not help you. And the longer the chain, the greater the chance that the data stops somewhere halfway.

Therefore, start with the suppliers with the longest or least transparent supply chains. That is where your risk lies, not with the party you know best.

The due diligence process

You first collect the mandatory information regarding legality, deforestation-free origin, geolocation, production date, and the involved supply chain partners. Then you assess the risk per country, per region, and per supplier individually. Where necessary, you take measures to demonstrably mitigate that risk.

• Collect information. Legality, deforestation-free, geolocation, production date, and the parties in the supply chain.
• Assess risk. Per country of origin, region, and supplier, with substantiation of your assessment.
• Mitigate risk. With additional checks, audits, satellite monitoring, or an alternative supplier.
• Record. Systematically archive decisions and evidence, with version control and references per shipment.
• Submit. As an operator, you submit the statement before the product enters the market.

What you establish with suppliers

The practical core of all this lies in your purchasing terms. Establish in them that the supplier provides coordinates and proof of legality, in what format this occurs, and within what timeframe. Add what happens if they fail to do so.

Without these agreements, you are dependent on goodwill at the moment you need the evidence. That moment almost always coincides with an order that needs to be shipped.

Where you start

Start with the scope. Create a product list with CN codes and mark what falls under the regulation. Then determine for each item who performs the first placement on the market, as that determines your role and thus the extent of your obligations.

1. Create a product list with CN codes and mark the items that fall within the scope.
2. Determine for each item whether you are an operator or a trader.
3. Request plot coordinates and legality documents from suppliers, including a deadline.
4. Assess the risk per origin and record your assessment in writing.
5. Perform a trial submission in the information system so that you encounter practical hurdles early on.