EUDR FAQ: Everything You Need to Know About the EU Deforestation Regulation

The EU Deforestation Regulation (EUDR), officially Regulation (EU) 2023/1115, is a landmark law aimed at eliminating deforestation-linked products from the European Union market. Adopted to address the EU’s role in global deforestation, the regulation requires companies to ensure that commodities like soy, palm oil, cocoa, timber, and others are both deforestation-free and legally produced. It introduces strict due diligence obligations, traceability requirements, and legal accountability for operators and traders placing relevant products on the EU market or exporting them from it. 

This FAQ-style guide provides a clear and structured breakdown of the EUDR’s core elements, including scope, deadlines, documentation, monitoring tools, legal implications, and sector-specific guidance. Whether you’re part of a sustainability team, procurement department, or legal office, this article is designed to help you understand and act on the EUDR’s practical demands before enforcement begins.

General Questions

This section explains the fundamentals of the EU Deforestation Regulation – what it is, when it applies, and why it matters globally. It lays the foundation for understanding the regulation’s logic and its role in sustainability legislation.

What is EUDR?

The EU Deforestation Regulation (EUDR), also known as Regulation (EU) 2023/1115, is a binding law adopted by the European Parliament and the Council. It prohibits the placing or export of specific commodities and their derived products in or from the EU unless they are proven to be:

• Deforestation-free, meaning the land used for their production has not been subject to deforestation after 31 December 2020.
• Produced in compliance with the local legislation of the country of origin.
• Covered by a due diligence statement (DDS) filed by the responsible company.

Unlike voluntary sustainability efforts, EUDR is enforceable by law, with real penalties for non-compliance. It applies to seven key commodities: cattle, cocoa, coffee, palm oil, rubber, soy, and timber – as well as a long list of products derived from them.

The regulation introduces a comprehensive framework of traceability, risk assessment, data submission, and monitoring. It also requires companies to maintain internal compliance systems and be prepared for audits from EU national authorities.

When does EUDR come into effect?

Although the EUDR formally entered into force on 29 June 2023, the actual obligations begin later, depending on the company’s size:

• 30 December 2025 for all large operators and traders (non-SMEs).
• 30 June 2026 for small and micro-enterprises.

These staggered dates were announced in a 2024 amendment and provide time for companies to develop internal systems, gather supplier data, and train staff.

It’s important to note that despite the deferred enforcement, competent authorities already expect companies to begin preparations. This includes identifying relevant products, mapping supply chains, and establishing due diligence processes. Waiting until the last moment increases the risk of market disruption and sanctions.

Why was the EUDR introduced?

The EUDR was introduced in response to a critical environmental challenge: the EU’s contribution to global deforestation. According to the European Commission, EU consumption is responsible for approximately 10% of global deforestation, particularly through the demand for soy, palm oil, beef, and timber.

In 2023 alone, the world lost 3.7 million hectares of tropical primary forests, equivalent to 10 football fields per minute. Much of this was driven by agriculture expansion – often linked to supply chains that feed into the EU market.

The EUDR aims to:

• Combat climate change by reducing emissions from land-use change.
• Protect biodiversity by preserving forest ecosystems.
• Encourage legal, sustainable supply chains globally.
• Hold businesses accountable for upstream practices.

By targeting both EU-based and non-EU actors, the regulation sends a clear signal: access to the EU market will depend on environmental compliance and transparency. It also aligns with broader EU policies like the Corporate Sustainability Due Diligence Directive (CSDDD) and the Green Deal.

Scope of the Regulation

This section outlines the range of products subject to the EU Deforestation Regulation and clarifies who is responsible for compliance. Understanding the scope is essential, as all EUDR requirements hinge on whether a product falls within the regulated categories and on the role the company plays in the supply chain – as either an operator or a trader.

What products are covered by EUDR?

The EUDR applies to a specific and carefully defined group of commodities that are scientifically linked to global deforestation and forest degradation. These include raw materials as well as a broad array of processed or derived goods. Crucially, the regulation applies not just to products composed directly of these commodities, but also to those that have been made using them, or fed with them, at any stage of production.

The seven core commodity groups regulated under EUDR are:

• Cattle: Includes beef, leather, gelatin, and other bovine-based products.
• Cocoa: Covers both raw and processed forms, such as cocoa paste, butter, powder, and chocolate.
• Coffee: Applies to green beans, roasted coffee, and instant coffee.
• Palm Oil: Encompasses crude and refined oil and all derivatives used in food, biofuel, and cosmetics.
• Rubber: Includes natural rubber and rubber-based products like tires and footwear.
• Soy: Covers soybeans, soy oil, soy meal, and soy-based animal feed.
• Wood: Regulates logs, sawn timber, plywood, pulp, paper, furniture, and wood-based panels.

Beyond this core list, the regulation also covers products that incorporate these commodities – for instance, a leather handbag or a chocolate bar – even if the commodity is just one of many ingredients. The rules extend to composite goods and processed items, provided they contain any proportion of a regulated input.

Several important exemptions and clarifications exist to prevent regulatory overreach. For example, packaging materials are excluded from EUDR scope unless they are made from regulated commodities (e.g., wood) and listed in Annex I. Recycled products may be exempt unless new regulated material has been added during reuse or repair. The regulation also uses Harmonized System (HS) codes – and where a code is marked with “ex,” only the portion relevant to the regulated commodity is subject to compliance. Notably, the product list is dynamic: the European Commission is required to review and potentially expand the list based on evolving environmental data and market impacts.

In practice, if a product contains, is made from, or relies on any of the seven commodities at any point in its lifecycle, it likely falls within the regulation’s scope – regardless of whether the commodity is visibly present in the final item.

Who must comply with EUDR?

The EUDR establishes legal responsibilities for companies based on their role in the supply chain, dividing them into two categories: operators and traders. The distinction is more than semantic – it determines whether a company must carry out due diligence or simply ensure that upstream compliance has occurred.

Operators are the companies that first place a regulated product on the EU market or export it from the EU. This includes manufacturers, importers, and processors – even when the transaction happens within the same corporate group but across legal entities. Operators bear the full compliance burden: they must collect the required data, perform risk assessments, and submit a formal Due Diligence Statement (DDS) before the product can legally enter or leave the EU market.

Traders, by contrast, are companies that distribute or sell regulated goods already placed on the EU market. This includes wholesalers, retailers, and B2B distributors. Traders do not need to perform their own due diligence but must verify that the operator has done so and retain the DDS reference for inspection.

Here is a simplified breakdown of responsibilities:

• Operators: Must conduct due diligence, submit DDS, retain all compliance records.
• Traders (large): Must collect DDS from suppliers and be able to present it to authorities.
• Traders (small/micro): Have no DDS obligation and cannot be forced to submit one by larger partners.

However, the line between operator and trader can blur. For example, a company that imports raw coffee beans is an operator. If it later roasts and sells them domestically, it may act as a trader – unless it sources new beans directly, in which case it reverts to operator status. Companies can hold both roles simultaneously for different product lines.

Non-EU companies, while not directly submitting DDSs, must actively cooperate with EU operators to supply all necessary compliance documentation. This makes EUDR a globally relevant regulation, not just an internal EU rule.

Does EUDR apply to small businesses?

Yes, small and micro-enterprises are covered by the EUDR, but the regulation acknowledges their limited capacity by offering tailored deadlines and reduced compliance burdens in certain cases. This proportional approach ensures that the regulation remains effective without creating undue barriers for small actors in the supply chain.

While all companies must comply in principle, the extent of their obligations depends on their size and function. The core compliance rules remain in place: small businesses that act as operators – meaning they place regulated products on the EU market or export them – must still conduct full due diligence and submit DDSs, just like large firms. However, they have an extended deadline of 30 June 2026, providing six extra months beyond the general enforcement date.

Small traders – those who do not place products on the market but merely distribute them – benefit from simplified rules. They are not required to submit DDSs and cannot be compelled by partners to do so. Their primary obligation is to ensure they only source from compliant operators and keep basic documentation.

Here’s the one summary list allowed in this section:

• Small operators: Full due diligence required, but enforcement may be more flexible.
• Small traders: No DDS required; cannot be forced to conduct due diligence.
• Support available: Capacity-building tools and technical guidance from the EU and Member States are being developed to help small actors comply.

It is important to stress that size alone is not an exemption. A small company that places a regulated product on the market must treat EUDR as binding law. Early preparation – including supplier outreach, geolocation collection, and internal system setup – will be essential to avoid future compliance risks or delays.

Due Diligence Requirements

This section explains the core obligation under the EUDR: due diligence. Every company subject to the regulation must implement a structured, verifiable process to prove that its products are both deforestation-free and legally produced. This obligation is not optional. Failure to comply can result in products being denied access to the EU market, as well as legal and financial penalties. The due diligence process includes three key steps – information gathering, risk assessment, and risk mitigation – and culminates in the submission of a formal Due Diligence Statement (DDS).

What is a due diligence statement?

A Due Diligence Statement (DDS) is a legal declaration submitted by an operator through the EU’s centralized Information System. It confirms that the operator has carried out a complete due diligence process in accordance with the EUDR, and that the product in question complies with all relevant criteria. The DDS must be submitted before a regulated product is placed on the EU market or exported from it.

The DDS must confirm:

• The product is deforestation-free (no deforestation has occurred on the land since 31 December 2020).
• The product was legally produced in compliance with applicable local laws.
• The operator has conducted a risk assessment and, where needed, implemented risk mitigation measures.

Once a DDS is submitted, it becomes locked if a competent authority launches a compliance check. At that point, no further edits can be made. This ensures the document is treated as an enforceable record. The DDS also carries a unique reference number, which must appear on all customs declarations involving the covered goods. In the case of consolidated shipments or batch trading, multiple DDS references may be linked within a single customs entry, simplifying logistics and documentation.

There are technical limitations to consider. A single DDS may contain up to 200 distinct products, reference as many as 1,000 production plots, and include over one million GPS coordinates – within a 25MB file size cap. The operator must also retain each DDS and all supporting documentation for at least five years, making this a long-term record of regulatory compliance.

What does the due diligence process involve?

The EUDR defines due diligence as a three-step process: information collection, risk assessment, and risk mitigation. Each step is mandatory and must be completed in sequence before a product can legally move through the EU’s regulatory gate.

Step 1: Information Collection

Operators must begin by collecting a complete dataset on every batch of products. This includes geolocation information, production timelines, commodity specifications, and documentation that proves legal compliance. For products with multiple inputs – such as chocolate or animal feed – information must be collected for each component, covering all geographic sources.

Step 2: Risk Assessment

With the data collected, the next step is to evaluate the likelihood that the product might be non-compliant. This involves reviewing country-level deforestation risk, satellite imagery, historical supplier behavior, and supply chain traceability. Even if a product originates from a “low-risk” country, basic due diligence must still be performed. Simplified procedures may apply, but companies cannot opt out entirely.

Step 3: Risk Mitigation

If any non-negligible risk is identified, the operator must take verifiable action to reduce it. This could include gathering more documentation, switching suppliers, or conducting audits. Only when the operator determines and can prove that the risk has been reduced to a negligible level may a DDS be submitted.

Here is a summary of the three mandatory due diligence steps:

• Collect verifiable data, including GPS coordinates, legal documents, and supplier information.
• Assess risks using tools like satellite maps, benchmarking, and supply chain analysis.
• Mitigate identified risks with targeted actions, ensuring they are documented and effective.

Each step must be completed before the product is allowed into or out of the EU market under the EUDR.

What data do companies need to collect?

To comply with the EUDR, operators must gather and retain a wide array of precise data points for every regulated commodity. This data is central to proving that the product was not linked to deforestation and was legally sourced. It must be complete, accurate, and traceable across the supply chain from the origin of the raw material to the final product.

Required data includes:

• GPS coordinates of every land plot involved in production.
• Production dates (harvest or lifecycle, depending on commodity).
• Commodity details: type, form, scientific name (for wood), and HS code.
• Net weight in kilograms, as required by EU customs authorities.
• Supplier and upstream supply chain information.
• Country and region of origin.
• Legal compliance documents, including permits and licenses.
• Traceability documentation if the product changed hands or was processed.

In addition, there are technical and procedural considerations. If a product is re-imported into the EU after previously being exported, the same DDS can be reused to avoid duplication. For companies with high shipment volumes, annual DDS submissions are now permitted – but only under defined regulatory conditions.

Here is the single list for this section, summarizing key obligations:

• Maintain accurate geolocation and legal production data for each plot.
• Submit DDS before placing products on the market or exporting them.
• Archive all due diligence documentation for five years.
• Use digital tools (e.g., satellite data, blockchain systems) to support traceability and verification.

Given the volume and specificity of the data required, many companies are turning to advanced traceability platforms, satellite mapping technologies, and integrated compliance software to manage the due diligence process efficiently. Coordinating legal, procurement, and sustainability teams is also essential to ensure that all obligations are met.

Monitoring and Reporting

Once a company completes its due diligence and places a product on the EU market, compliance efforts do not end there. The EUDR requires continuous monitoring, documentation, and the ability to demonstrate if audited that the product is truly deforestation-free and legally produced. This section outlines how companies can prove their compliance, which technologies can support these efforts, and the role (if any) of third-party verification in the process.

How do companies prove their products are deforestation-free?

To demonstrate that a product complies with the EUDR, operators must present robust, traceable, and verifiable evidence that no deforestation or forest degradation occurred after 31 December 2020. This requirement is batch-specific, meaning each shipment or product group must be individually documented. The process relies on geospatial data, legal records, and historical land-use validation.

The foundation of proof is geolocation: every land plot involved in production must be identified by exact coordinates, often using polygons or points depending on the commodity. These coordinates must match the relevant production period – whether it’s harvesting for timber, planting for soy, or animal grazing cycles for cattle. Satellite imagery is then used to cross-validate that no tree cover loss or land conversion has taken place since the cut-off date. Accepted tools include the EU’s Copernicus program, Global Forest Watch, and national forest monitoring systems.

Operators also need to demonstrate that land use is legally permitted in the country of origin. Documents such as land ownership titles, environmental permits, and zoning records are typically used. In certain cases, historical data showing land was already under agricultural use before the cut-off date can strengthen a company’s compliance position.

The required types of evidence include:

• Geolocation data for all production plots, matched to timelines.
• Satellite imagery confirming forest status has not changed since 2020.
• Land-use documents showing legal rights to produce on the land.
• Historical land-use records proving agricultural activity pre-2020.
• Risk assessment results supporting a negligible risk conclusion.

Together, these sources form a complete “evidence package.” Importantly, the burden of proof lies with the operator not with customs officials or market authorities making proactive record-keeping and documentation essential.

What platforms or tools can be used?

Complying with the EUDR’s traceability and verification requirements is highly data-intensive. Manual record-keeping is not feasible for most companies, especially those handling multiple commodities across complex supply chains. Instead, businesses must rely on a combination of digital tools and data platforms to ensure accuracy, scalability, and compliance-readiness.

The most critical technologies include satellite monitoring systems that provide real-time imagery and forest alerts. These help operators detect early signs of land-use change and track developments around their sourcing areas. Beyond satellites, geospatial platforms are used to manage and map sourcing plots, while supply chain mapping tools help track movement and custody across all supply chain nodes.

Digital ledgers and blockchain technologies, though not mandatory, are increasingly used to enhance traceability and secure records. Supplier data platforms, equipped with APIs, automate the collection of documentation, monitor supplier behavior, and alert companies to gaps or inconsistencies. Lastly, the EU’s official TRACES system serves as the interface for submitting Due Diligence Statements and linking them to customs procedures.

Key tools supporting EUDR compliance include:

• Satellite monitoring platforms.
• Geospatial supply chain mapping systems.
• Blockchain-based traceability solutions.
• Supplier management platforms with real-time data validation.
• The EU’s TRACES Information System for DDS submissions and record keeping.

Using these platforms improves consistency, reduces administrative burden, and strengthens the credibility of due diligence efforts especially in the case of regulatory audits or partner evaluations.

Is third-party verification required?

One of the more frequently asked questions about the EUDR is whether companies are required to engage a third-party auditor to certify that their products are deforestation-free. The simple answer is no: third-party verification is not mandatory under the regulation. However, it can be a valuable component of a strong risk mitigation strategy, particularly in cases where the risk of non-compliance is higher.

For operators sourcing from countries designated as “standard” or “high risk” under the EU’s benchmarking system, the use of third-party audits, external certifications, or verification services is strongly recommended. These external checks can help confirm supplier reliability and supplement the operator’s own data analysis. Widely used schemes like FSC, PEFC, and Rainforest Alliance may provide helpful documentation, although they cannot replace due diligence or DDS submission.

Importantly, even when third-party verifiers are used, legal responsibility remains fully with the operator. Certification does not transfer liability or reduce regulatory obligations.

Third-party verification under EUDR is:

• Optional, but recommended in higher-risk sourcing contexts.
• Useful when based on credible schemes (e.g., FSC, PEFC) or independent audits.
• Not a substitute for internal due diligence or DDS requirements.
• A strategic tool for increasing transparency, audit readiness, and customer trust.

In summary, while not legally required, third-party verification offers practical benefits for businesses seeking to enhance compliance and minimize reputational risk. It is best used to complement not replace a well-built internal due diligence system.

Legal and Enforcement Questions

The EU Deforestation Regulation (EUDR) is legally binding and enforceable. It is not a voluntary sustainability initiative but a law with serious implications for companies that fail to comply. Understanding how enforcement works, what penalties may apply, and what legal responsibilities fall on businesses is essential for risk management, especially for companies placing or exporting relevant products to or from the EU market.

What happens if a company does not comply?

Failure to comply with EUDR can result in severe legal and financial consequences. EU Member States are empowered to determine and apply sanctions through their national legal systems. However, the Regulation itself mandates that all penalties must be “effective, proportionate, and dissuasive,” ensuring that non-compliance is not treated as a minor regulatory lapse.

The consequences of non-compliance include a range of administrative and legal actions:

• Financial penalties based on the product’s market value or company size.
• Seizure of goods at customs or from warehouses.
• Market withdrawal and possible destruction of non-compliant products.
• Temporary or permanent bans from placing goods on the EU market.
• Legal prosecution in cases involving fraud or falsified documentation.

These penalties are designed not only to punish violations but to deter negligence or willful avoidance of due diligence. Repeated or intentional breaches may lead to more severe measures, such as the blacklisting of the company within the EU Information System, which would restrict or entirely block their access to the EU market.

Furthermore, non-compliance can lead to significant reputational damage. Investors, consumers, and supply chain partners may withdraw from partnerships to avoid risk exposure. This is especially critical in sectors where environmental transparency is a market expectation.

The key message: investing in full EUDR compliance is not just a legal necessity but a business continuity safeguard.

How will the EU check compliance?

The enforcement of EUDR is built on a dual structure: centralized digital systems and decentralized Member State authorities. This combination ensures that due diligence claims are continuously monitored, verified, and, if necessary, investigated.

At the heart of the process is the EU’s central Information System, where operators must upload their Due Diligence Statements (DDS). This system stores all product-related data and serves as the foundation for cross-checks by national authorities. DDS submissions are linked to customs procedures, making them accessible during trade inspections.

National authorities in each EU Member State are responsible for carrying out compliance checks. They conduct audits, inspections, and data validations, including site visits if necessary. Their monitoring strategies are often risk-based, focusing on high-risk countries, sensitive commodities like soy and palm oil, or companies with high trade volumes.

Enforcement activities typically involve:

• Audits based on DDS and supporting documents.
• Satellite imagery reviews against geolocation data.
• Supply chain traceability checks and field investigations.
• Real-time customs verification through DDS reference numbers.

A particularly important feature is the “locking” of a DDS once an investigation begins. This means the data cannot be altered or deleted during a compliance review, ensuring audit integrity. This system of preventive and reactive enforcement supports the credibility and impact of the Regulation.

Operators should expect both random inspections and targeted audits based on red flags or substantiated concerns raised by civil society or other stakeholders. Even companies operating in low-risk regions are not exempt from scrutiny.

How long should data be stored?

Under Article 18 of the EUDR, all data related to due diligence must be retained for a minimum of five years. This includes not only the Due Diligence Statement itself but all supporting documentation and evidence used in the assessment process.

This data retention rule applies equally to operators and traders. Operators are those who place products on the market or export them, and they must retain all records of due diligence they conducted. Traders, if not required to conduct their own due diligence, must still store the DDS reference numbers and supporting materials received from suppliers.

The categories of information that must be archived include:

• Submitted DDSs and any linked or referenced documents.
• Geospatial files used to verify deforestation-free status.
• Legal documentation such as land use permits and supplier contracts.
• Risk assessments and mitigation logs.
• Communication records with suppliers and third parties.

Digital storage is acceptable and even encouraged, but the system used must ensure accessibility, security, and audit readiness. That means files must be organized, searchable, and backed up. Companies are advised to implement alerts for data expiration and ensure that historical records are not overwritten or deleted accidentally.

Failure to provide this information during an audit or investigation – even if the original due diligence was correct may itself be considered a breach of the Regulation. For this reason, data retention should be viewed as an essential component of long-term compliance and legal protection.

Sector-Specific QuestionsTimeline and Transition

The EUDR introduces binding requirements and firm deadlines, but also recognizes the diverse nature of affected industries and company sizes. This section clarifies when companies need to comply, what sector-specific challenges exist, and how certification schemes like FSC, PEFC, and Rainforest Alliance fit into the EUDR framework.

When should companies start preparing?

Companies must begin EUDR compliance preparations immediately, even if the regulation’s core obligations only become enforceable starting 30 December 2025 for large companies and 30 June 2026 for small and micro-enterprises. This urgency is due to the significant operational, legal, and technical transformations required to meet the due diligence obligations, including supplier engagement, data collection, and geospatial verification.

The steps involved in readiness are time-consuming and cross-functional, often requiring coordination across procurement, legal, IT, compliance, and sustainability departments. Additionally, companies may face challenges in sourcing accurate geolocation data, especially from upstream producers in countries with limited technical infrastructure. These issues are exacerbated when supply chains involve aggregation, cooperatives, or intermediaries.

Key reasons companies should begin now include:

• Supply chain mapping and traceability often involve multiple tiers of suppliers and intermediaries.
• Geolocation data collection and validation require advanced GIS tools and technical expertise.
• Internal systems must be upgraded to accommodate data processing, documentation, and integration with the EU’s TRACES platform.
• Supplier onboarding, education, and substitution strategies may need months to implement.
• Product access to the EU market will be blocked if DDS submissions are incomplete or incorrect.

Starting with high-risk commodities like soy, beef, cocoa, or palm oil is a strategic way to prioritize resources and reduce future compliance risks.

Is there a grace period?

The EUDR does not include a formal grace period. Instead, it sets clear phased enforcement deadlines: 30 December 2025 for large operators and traders, and 30 June 2026 for small and micro-enterprises. This phased timeline provides companies with some lead time, but enforcement will be immediate once the deadlines pass.

During the transition period, authorities may focus more on education and outreach, particularly for SMEs. However, there is no exemption or leniency written into the Regulation. Companies that fail to comply after the deadline – including missing DDS submissions or incomplete due diligence will face enforcement actions.

Important facts about the transition timeline include:

• No exceptions are made for pre-existing stock unless it was placed on the market before the deadline.
• All Annex I products are equally covered – there are no product-based exclusions.
• National customs authorities and EU systems like TRACES are already active and accepting data.
• NGOs and watchdog organizations are monitoring market behavior and may file substantiated concerns to trigger investigations.

Thus, the lack of a grace period reinforces the need for immediate preparation, especially for complex or high-volume supply chains.

Will there be updates to the regulation?

Yes, the EUDR is structured as a living framework – designed to evolve based on new data, stakeholder input, and environmental developments. The European Commission is actively managing updates and will continue to refine the Regulation in response to implementation feedback and deforestation trends.

The most likely areas for change include:

• Annex I product list updates: More commodities and derived products may be added, such as sugarcane or maize, based on deforestation linkage data.
• Country benchmarking: The classification of countries as high-risk, standard-risk, or low-risk will evolve as conditions change, affecting due diligence requirements.
• Technical guidance and FAQs: Additional clarifications will be issued regularly to address practical implementation challenges and definitions.
• TRACES IT system updates: New features will enhance batch management, multi-language support, API access, and integration with corporate systems.
• Policy alignment: The EUDR may be harmonized with other EU directives like CSRD, CSDDD, and the Green Claims Directive to streamline corporate reporting obligations.

Stakeholders should also be aware that the European Commission conducts consultations with industry, NGOs, and Member States. Participating in these dialogues allows companies to anticipate changes, provide input, and influence the direction of future updates.

Monitoring regulatory communications and subscribing to official updates are essential compliance practices. Companies that build flexible systems will be better positioned to adapt as the regulatory environment evolves.

How does EUDR affect the coffee, cocoa, and wood industry?

The coffee, cocoa, and wood sectors face some of the greatest compliance challenges under the EUDR due to their global reach, traceability difficulties, and historic links to deforestation. While the regulation applies the same legal standard to all commodities, the practical impact varies across these industries.

Coffee

Coffee is primarily sourced from smallholder farmers in tropical countries, where enforcement capacity is often weak. Complex supply chains involving cooperatives and intermediaries make it hard to isolate the geolocation of individual farms. Additionally, beans from multiple farms are often mixed during post-harvest processing, making origin traceability more complex.

To comply, coffee operators must:

• Map each supplying plot using GPS coordinates.
• Engage cooperatives in collecting farm-level data.
• Eliminate the use of mass balance systems in favor of physical segregation.
• Use field audits and satellite verification tools to confirm no deforestation occurred.

Cocoa

Cocoa is largely grown in West African nations that are high-risk for deforestation. Plantations are sometimes located close to protected areas, and aggregation during drying and fermentation creates challenges for traceability.

Operators must:

• Document geolocation for each cocoa plot.
• Validate records using imagery and legal land-use data.
• Offer capacity-building to smallholders on GPS and compliance.
• Rely on certification only as a supplement not as a replacement for due diligence.

Wood

The wood sector presents different risks, especially forest degradation rather than outright deforestation. Complex supply chains involve logging companies, processors, and traders. Legal documentation is often fragmented, especially in high-risk countries, and verifying origin requires both permits and geospatial data.

Key strategies for compliance include:

• Collecting polygon geolocation data for entire forest plots.
• Retaining licenses, transport records, and harvesting permits.
• Verifying that legal harvest does not result in primary forest conversion.
• Ensuring chain-of-custody is maintained across all transformation stages.

All three sectors must build systems for traceability, supplier accountability, and verification. Composite sourcing and mass balance are not allowed even for certified goods and physical segregation must be proven at the batch level.

Are FSC, PEFC, or Rainforest Alliance certifications accepted?

Certification schemes are widely used in deforestation-sensitive industries, but under EUDR, they do not replace the operator’s legal obligations. The regulation is explicit: certifications are optional tools, not regulatory exemptions.

Operators must still complete full due diligence regardless of certification status. That includes collecting geolocation data, performing a documented risk assessment, and submitting a valid Due Diligence Statement (DDS) for every relevant product batch.

Certifications can be helpful in specific ways:

• They may provide reliable supplier records and audit reports.
• Some schemes include sustainability metrics that support risk scoring.
• Certified suppliers may show better legal compliance and transparency.

However, the effectiveness of a certification depends on its rigor, independence, and recentness. Not all certification schemes are equal, and none are automatically accepted under EUDR. Mass balance models used in some schemes are explicitly disallowed under the regulation.

Operators should also note:

• Chain-of-custody models must support full traceability identity-preserved or segregated models are preferable.
• Certifications can assist in mitigation but cannot be used as a blanket justification for low risk.
• Legal responsibility for compliance always remains with the operator, even if third-party auditors or certifiers are used.

In conclusion, certification schemes are a valuable supplement but never a substitute for due diligence. They may strengthen a company’s internal systems and supplier relationships, but compliance under EUDR depends on direct evidence, verified data, and legally sound processes.

How to Get Help

Navigating the EUDR can be complex, especially for companies with fragmented supply chains, limited technical expertise, or constrained resources. This section outlines where to access official regulatory materials, how to engage external support, and how responsibilities should be distributed internally to ensure full legal compliance with the EUDR.

Where can I find official guidance?

The most authoritative source of EUDR-related information is the European Commission’s Environment portal, specifically the section dedicated to Deforestation Regulation Implementation. This platform houses a comprehensive library of resources that companies can use to understand and implement the regulation correctly.

Operators and traders should begin by thoroughly reviewing the legal text of Regulation (EU) 2023/1115, which lays out definitions, obligations, deadlines, and enforcement provisions. While dense, this regulation forms the legal foundation of all compliance work.

To assist companies in interpreting and implementing the regulation, the Commission has published additional supporting documents, such as FAQs, technical guidance, and implementation regulations. These materials explain how to gather and assess geolocation data, interpret key terms like “placing on the market” or “forest degradation,” and interact with the TRACES platform.

Key sources of official information include:

• The core Regulation (EU) 2023/1115 defining scope, definitions, and obligations.
• The Implementing Regulation detailing technical procedures and country benchmarking.
• Official FAQs offering practical clarifications and sector-specific advice.
• Guidance documents on traceability, satellite verification, and DDS submission.
• The country benchmarking methodology, published as a Staff Working Document, used to assess supply origin risk.

All of these resources are available via the Green Forum and the European Commission’s official websites. They are updated regularly, and companies are advised to monitor them continuously to stay ahead of changes.

Are there service providers who help with compliance?

Yes, a growing network of service providers offers targeted solutions to help companies navigate EUDR requirements. These include digital platforms, geospatial analysts, legal advisors, and verification services. Outsourcing parts of the due diligence process is especially useful for companies without in-house expertise in supply chain mapping or satellite analysis.

The range of services includes technology platforms that support traceability and geolocation, cloud systems for DDS generation, and audit firms that perform third-party verification and supplier readiness assessments. Some providers specialize in specific commodities or geographies, while others offer end-to-end compliance management.

Main categories of EUDR support services:

• Satellite monitoring and GIS-based mapping platforms for identifying and verifying land use.
• Due diligence software for collecting, storing, and submitting DDS and related compliance documentation.
• Supply chain mapping and traceability tools with API integration to internal procurement or ERP systems.
• Verification firms that conduct supplier audits, documentation reviews, and field inspections.
• Legal consultancies providing regulatory interpretation, contract adaptation, and internal governance reviews.

When selecting a service provider, companies should assess their internal compliance gaps, evaluate the provider’s technical capabilities, and ensure alignment with EUDR’s regulatory and data requirements. Clear contractual terms and defined service-level expectations are essential, especially when delegating critical compliance functions.

Who is responsible inside a company?

EUDR compliance is a shared effort across multiple departments, but legal responsibility ultimately lies with the operator and the entity submitting the Due Diligence Statement (DDS). While internal tasks can be distributed, the named operator remains accountable for the truthfulness and completeness of all submitted data.

Most companies structure their compliance response around a cross-functional working group that includes legal, procurement, sustainability, and IT stakeholders. The goal is to create a clear division of responsibilities while ensuring that all teams collaborate around a shared compliance framework

Key internal roles and their responsibilities:

• Sustainability / ESG team: Oversees strategy, supplier engagement, and alignment with broader environmental objectives.
• Procurement / Supply chain: Gathers origin and supplier data, negotiates compliance clauses, and ensures contract-level traceability.
• Legal and compliance: Validates DDS content, conducts internal audits, and ensures obligations are met under EU and national law.
• IT / Data management: Develops or integrates systems to store, manage, and transmit geolocation and supply chain data to TRACES.
• Executive leadership: Approves budgets, sets risk tolerance, and ensures accountability at the highest level including potential legal exposure.

Best practice dictates that companies designate a central EUDR Program Manager or a Chief Sustainability Officer (CSO) to oversee all compliance activities. This individual should report directly to senior leadership and coordinate across departments. For larger organizations, the creation of a dedicated EUDR task force with KPIs and clear escalation procedures is highly recommended.

In the end, even if multiple employees and vendors are involved, the operator as defined in the regulation carries the full legal burden. Therefore, careful internal alignment, robust documentation, and proactive oversight are essential.

Need Support with EUDR Compliance?

Navigating the full scope of the EU Deforestation Regulation can be challenging, especially with the 2025 enforcement deadline fast approaching. EUDR.co provides a practical guide and actionable resources tailored to help businesses understand and fulfill their compliance obligations. By breaking down the regulation’s key requirements into clear steps and timelines, the platform enables companies to move from uncertainty to confident execution. Whether the focus is on cocoa from West Africa, rubber from Southeast Asia, or timber with complex supply chains, EUDR.co helps align operations with due diligence standards in an efficient and structured way.

The EU regulation places the burden of proof directly on companies and demands high standards for traceability, legality, and risk mitigation. EUDR.co is built to support these expectations through tools for data collection, geolocation mapping, compliance strategy planning, and statement submission. The platform combines regulatory expertise with real-world application, offering businesses a reliable roadmap for navigating this evolving legal framework. Designed to simplify complexity and reduce risk, EUDR.co helps ensure companies stay compliant, competitive, and prepared for a deforestation-free future.

Conclusion

The EU Deforestation Regulation (EUDR) marks a pivotal change in how companies must approach supply chain due diligence, requiring verifiable proof that products are deforestation-free and legally produced. This is more than a compliance task – it demands strategic, cross-functional effort and the adoption of transparent, traceable systems across global sourcing networks. For professionals in procurement, legal, sustainability, and operations, the EUDR presents both a challenge and an opportunity: to mitigate regulatory risk, enhance supply chain integrity, and lead in environmental accountability. Businesses that act early and build robust systems will not only meet legal requirements but also gain long-term credibility in an increasingly climate-conscious market.