EU Deforestation Regulation (EUDR) Readiness Solution

Software platforms are powerful, but they do not automatically validate the accuracy, relevance or sufficiency of evidence. Software typically helps you collect supplier declarations, store farm lists and geolocation files, run automated risk screening, generate dashboards and due diligence workflows, and centralize documentation.

Readiness support adds the verification layer on top, we:

• Assess whether origin evidence is credible
• Evaluate whether the data corresponds to the declared production reality
• Review the assumptions, data sources and conclusions behind the results
• Test whether governance, responsibilities and escalation controls operate effectively
• Test volume, product flow and traceability controls
• Assess whether decisions are documented, justified and consistently applied

Where due diligence is required, your organization should be able to explain, document and justify your no-or-negligible-risk conclusion. For downstream operators and traders, readiness includes the information, recordkeeping, traceability and escalation controls applicable to their role.

Companies cannot build a reliable EUDR due diligence process if the product scope and product-flow logic are unclear. Notable areas include:

• Harmonized System (HS)/Combined Nomenclature (CN) code uncertainty: confirm whether the product falls under a CN code listed in Annex I and document the classification basis
• Derived products and ingredients: determine whether processed products, derivatives or ingredients remain covered, based on their Annex I classification and composition
• Packaging and composite products: assess whether packaging is, itself, placed on the market as a relevant product and whether composite products contain components subject to the EUDR
• Recycled or secondary materials: verify whether the material qualifies as waste, recycled or previously used and whether any virgin relevant commodity remains within scope
• Products placed pre-application date: establish when the product was placed on the market or exported, and whether transitional provisions or supporting evidence apply
• Transformation and reimport scenarios: trace whether an EUDR-covered product was transformed, exported or reimported, and determine which actor and product stage carries the obligation

The EUDR does not apply to every product containing agricultural or forest materials. Coverage depends on whether the product falls under a CN code and description listed in Annex I, and meets the associated commodity description.

The legal obligation often sits with EU actors while the critical data sits upstream and outside the EU. Common bottlenecks include:

• Smallholder and cooperative sourcing
• First aggregators and dealer networks
• Mills, warehouses and mixed-origin flows
• Commercial sensitivity around supplier disclosure
• Volume reconciliation between production plots and shipments
• Data held in paper files, the local language or informal systems

Organizations therefore need evidence that traceability information is complete, consistent and connected to the relevant product flow.

The first mile is where origin, legality, land-use history and supplier reality meet:

• What companies often have: supplier declarations, farm lists, certificates, maps, screenshots, document uploads and platform risk scores
• What they still need to know: whether the farm, producer, land area, product flow and legality evidence are credible in the local context
• When to escalate: high-risk documents, unclear traceability, weak geolocation, supplier resistance, substantiated concerns or inconsistent volumes

We can use local knowledge and, where included in the agreed scope, on-site verification to assess whether the producer, production area, geolocation, legality evidence and product flow are consistent with the declared origin.

Relevant legislation is country-specific and the credibility of documents depends on the local context:

• Land-use rights: ownership, tenure, concessions, customary rights, lease agreements or producer registration
• Environmental protection: environmental permits, protected areas, land-conversion restrictions, biodiversity requirements and applicable environmental impact obligations
• Forest-related rules, where directly related to wood harvesting: legal harvesting rights, forest management plans, harvesting permits, authorized species and volumes, biodiversity conservation, protected habitats, regeneration or replanting requirements and restrictions on harvesting methods
• Labor and human rights: labor laws, working conditions, occupational health and safety, freedom of association, prohibition of forced and child labor, worker rights and applicable social obligations
• Tax, trade and customs: business registration, tax status, applicable fees and royalties, harvest and transport permits, customs documentation and export requirements
• Third-party rights: the rights of indigenous peoples, local communities and other affected parties, including land, resource, access, use and customary rights, where applicable
• Free, prior and informed consent, including applicable indigenous peoples’ rights: evidence of consultation through legitimate representative institutions, timely disclosure of relevant information, documented consent or agreements, community participation, grievance processes and respect for rights to lands, territories and resources
• Anti-corruption/governance: fraud and corruption risks, conflicts of interest, document authenticity and integrity, improper payments, the reliability of official approvals and relevant local administrative controls

We assess the relevance, reliability, consistency and local adequacy of legality evidence. The assessment supports your due diligence process but does not constitute a legal opinion.

A location file must be technically plausible and linked to the correct production reality.

• Points used where polygons are needed
• Boundaries include roads, villages, water or neighboring farms
• The ownership area differs from the production area
• Forest datasets disagree or are misread
• Tree crops and agroforestry are misclassified
• The December 31, 2020, deforestation cutoff assessment is not documented

Our geospatial review assesses whether the data, methodology, assumptions and technical conclusion provide credible support for the applicable due diligence decision.

In many organizations, the EUDR is split across departments, creating weak accountability. This is often considered a “hidden risk”.

• Procurement: supplier data and commercial pressure
• Legal: interpretation and liability concerns
• Sustainability: policy, reporting and external commitments
• IT/SaaS: platform workflows and integration
• Customs: product codes and due diligence system/customs interface
• Quality/compliance: supplier files, audits and corrective actions

For an operator required to exercise due diligence, responsibility for approving the no-or-negligible-risk conclusion should be clearly assigned. Procurement, legal, sustainability, customs, quality and IT may contribute information, but the organization should define who approves the conclusion, authorizes mitigation and controls the applicable regulatory submission.

Downstream operators and traders should define responsibilities for supplier and customer information, recordkeeping, traceability and escalation of potential non-compliance.

Our readiness solution is supported by three structured assessment tools covering 233 control points.

Pillar 1: due diligence system assessment

Does the company have the governance, procedures and controls needed for the EUDR?
This includes:

• Product scope and role classification
• Governance and responsibilities
• Risk logic and mitigation process
• Due diligence system/declaration readiness
• Record retention and escalation
• 10 principles, 108 control points

Pillar 2: first mile/farm/forest assessment

Is the declared origin, geolocation and legality evidence credible? This includes:

• Origin evidence
• Producer credibility
• Geolocation and no deforestation
• Legality evidence and local context
• First-mile traceability
• 9 principles, 61 control points

Pillar 3: traceability and chain of custody review

Can the product flow be linked to the origin and due diligence system evidence? This includes:

• Supply chain flow
• Movement, storage and transformation
• Mixing and splitting controls
• Volume reconciliation
• Transfer and retention of supplier, customer and regulatory reference information, where applicable
• 6 principles, 64 control points

Supporting service: training

Can teams and suppliers implement the process consistently? This includes:

• Role-specific EUDR training
• Internal team capability building
• Supplier awareness and implementation support
• Training effectiveness evaluation, where included in the scope

Escalation logic: desk review, supplier clarification, local expert/auditor review and field verification where risks remain unresolved.

Yes. Our approach is platform-neutral. We can assess the governance, data quality, user controls, risk rules and transaction records associated with your existing system.

Where appropriate, complementary technologies, such as geospatial analysis, traceability tools or scientific origin testing, may be considered, subject to technical applicability and availability. Solutions may include:

1. Traceability throughout the supply chain: end-to-end visibility of materials and products across complex supply chains
2. Deforestation analysis: advanced satellite monitoring and AI-driven insights to detect and assess deforestation risk
3. Digital product passport (DPP): digital records that enhance transparency, compliance and product sustainability data
4. Isotopic fingerprinting: scientific isotopic analysis to verify the geographic origin of materials

Our solution can support the EUDR pathway, from product and role classification, origin, legality, geolocation and traceability controls to risk assessment and the applicable regulatory submission.

1. Product scope
2. Role and obligation classification
3. Origin validation
4. Geolocation and deforestation-free assessment
5. Legality evidence
6. Chain of custody
7. Risk assessment and mitigation, where required
8. Due diligence statement or simplified declaration readiness, where applicable

The full pathway can be an integrated readiness program or targeted modules, depending on the risk and client maturity. For downstream actors, the scope should focus on the information, recordkeeping, traceability and escalation controls applicable to their role.

Different organizations enter the readiness pathway according to their activities, product flows and current level of maturity:

• Operators conducting due diligence may require a complete review of product scope, origin evidence, their due diligence system, risk assessment, mitigation and regulatory-submission readiness
• Downstream operators and traders may require supplier and customer records, chain of custody controls, traceability, regulatory-reference controls, where applicable, and non-compliance escalation
• Manufacturers, retailers and brands may perform different EUDR roles for different products. We can help classify each product flow and define the appropriate assessment scope
• Producers and suppliers outside the EU may require first-mile, legality, geolocation and traceability support to provide credible evidence to their customers
• Certification clients may require a gap assessment between existing certification evidence and EUDR requirements

The same framework can serve operators, downstream actors, retailers, producers and certification clients without forcing a rigid service package.