The mandatory implementation of the EUDR requirements is now here. After several postponements, the EU has stated that December 30, 2026, is the start date with no further delay.
One of the biggest difficulties posed by the EUDR is not only understanding what the regulation requires but also applying it to real situations. In many companies, doubts arise when analyzing a specific product or supplier, an import operation, a sale within the EU or a supply chain with several intermediaries.
This is not a minor issue. The EUDR requires affected organizations to demonstrate that certain products and raw materials are deforestation-free, comply with applicable legislation in the country of production and provide sufficient information to support due diligence.
In practice, this means that companies must review how they buy, what information they receive from suppliers, what traceability they have concerning product origin and what role they play in the chain: operator, downstream operator or trader.
The EUDR affects commodities, including wood, soy, cocoa, coffee, rubber, palm oil and cattle, as well as certain derived products. However, the impact is not the same for every company.
One organization may be affected because it imports an in-scope product. Another may be involved because it transforms a raw material already placed on the EU market. Another may act as a distributor or trader. Even the same company may have different roles depending on the product, commercial flow or supplier.
That is why preparation for the EUDR should not be approached through a generic question, such as “Does it apply to me or not?” The more useful question is, “In which concrete cases could it apply to my company and what information do I need to demonstrate this?”
The first step is to check whether the product is related to any commodities covered by the regulation and whether it falls within the relevant products included in its scope.
It is not enough to review the product’s commercial name. Its composition, use, customs code, origin and relationship with the affected commodities must be analyzed.
Yes, this may happen. The EUDR not only affects companies that import raw materials from outside the EU. It can also impact manufacturers, processors, distributors, retailers or companies that make affected products available on the market.
The key is to identify the company’s real role within the chain. Under the EUDR, the role depends on what is done with each product.
The operator is the actor that places an in-scope product on the EU market or exports it from the EU. The downstream operator participates in later stages of the chain and may use relevant products already on the market to manufacture, transform or commercialize other affected products. The trader makes EUDR products available without necessarily being the actor that first places them on the market.
This distinction determines what information the company must collect, what references it must retain and what level of responsibility it assumes concerning due diligence.
Having a previous statement or reference can help, but it does not mean that the company can disengage from the process. Downstream actors must be able to link their products, lots or operations to the information received.
The risk lies in treating the reference as a generic document. To be useful, it must form part of coherent and verifiable traceability.
It will depend on the product, the company’s role and the supply chain. Generally, it may be necessary to collect information on product origin, geolocation data, supplier, country of production, legal documentation, traceability, due diligence references and evidence supporting risk assessment.
The difficulty is not only asking for information, but knowing what information is relevant, how to validate it and how to retain it.
As the EU indicates, having traceability and chain of custody certifications, such as PEFC, FSC™, RSPO, etc., does not exempt companies from meeting the different requirements, although they clearly help in being prepared or as mitigation actions for the associated risks required by the due diligence process that must be established.
Geolocation is one of the most sensitive aspects of the EUDR because it links the product to its place of production. If a supplier cannot provide this information, the company must identify the gap and assess the risk involved.
It may be necessary to work with the supplier to improve traceability, look for alternative sources of information or review whether the supply chain is prepared to meet the regulation’s requirements.
Customs codes may be relevant to determine whether a product falls within the scope. For this reason, customs and technical review are important to the diagnosis.
The recommendation is to coordinate between technical, commercial, logistics and customs areas to avoid isolated interpretations.
Transformed products can raise questions because the original raw material is not always evident. However, if the final product is in scope, the company must demonstrate the connection with the origin information and the corresponding due diligence references.
In mixed products, formulations or chains with several suppliers, traceability can be more complex. The goal is not only to retain documents but also to reconstruct the logic of the supply chain.
Not all logistics companies will have the same obligations, but they may be involved in document management, traceability or coordination of information between actors in the chain.
It is important to analyze the service each company provides: transport, storage, customs clearance, import, distribution or integrated supply chain management. Depending on that role, it may need to provide information, retain evidence or coordinate with operators and traders.
The first step should be a diagnosis. Before designing complex procedures, it is advisable to identify which products may be affected, what role the company plays in each flow, what information already exists, what data is missing and which suppliers present greater risk or complexity.
From there, priorities can be set. Not all chains will have the same urgency or level of exposure. Preparation for the EUDR must be progressive, realistic and evidence-based.
One of the most common mistakes is thinking that the EUDR only applies to importers of raw materials. Many companies that manufacture, transform, distribute or commercialize derived products may be affected.
It is also common to assume that receiving a supplier statement is enough. Although that information may be necessary, the company must be able to relate it to its operations and retain sufficient evidence.
Preparation should begin by understanding the starting point. This means analyzing products, suppliers, roles, commercial flows, available documentation and internal systems.
From there, it is possible to identify gaps against EUDR requirements and define a roadmap: procedure review, supplier questionnaire updates, traceability improvement, documentation analysis, internal training and coordination between areas.
We can help organizations analyze real EUDR application cases, identify affected products, determine the company’s role in each supply chain and assess the maturity level of their processes.
Through EUDR gap analysis and specialized traceability and chain of custody services, we provide an independent technical perspective to detect gaps, prioritize actions and prepare compliance in a structured way.
In EUDR, answers are not always generic, so compliance begins by understanding each concrete case.
For further information, please contact:
Jan Pierre Jarrin Peters
Product Manager EUDR
t: +31 (6) 10881016
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