EUDR Compliance: A Practical Guide to the EU Deforestation Regulation
The European Union Deforestation Regulation (EUDR) introduces new requirements for companies placing certain commodities and products on the European Union market or exporting them from the EU. The regulation is designed to reduce the EU's contribution to global deforestation and forest degradation while requiring companies to demonstrate that relevant products were produced legally and are not linked to deforestation or forest degradation.For businesses involved in commodities such as cattle, cocoa, coffee, palm oil, rubber, soy and wood, EUDR compliance requires more than collecting supplier declarations. Companies need to understand which products are covered, identify their origin, collect relevant supply-chain information, assess potential risks and, where necessary, take measures to reduce those risks before the products enter the EU market or are exported.
This guide provides an overview of the main elements of EUDR compliance, including due diligence, geolocation, risk assessment, supply-chain traceability and Due Diligence Statements.
What Is the EU Deforestation Regulation?
The EU Deforestation Regulation, formally Regulation (EU) 2023/1115, establishes rules for certain commodities and products associated with deforestation and forest degradation.The regulation applies to relevant products placed on the EU market, made available on the EU market or exported from the EU, subject to the specific roles and requirements established by the regulation.
The central objective is straightforward: relevant products must not be associated with deforestation or forest degradation occurring after 31 December 2020, and they must have been produced in accordance with the relevant legislation of the country of production.
EUDR therefore combines environmental requirements with supply-chain due diligence and traceability.
Instead of relying only on the identity of a supplier or the country from which a product was purchased, companies may need to establish where the relevant commodity was actually produced and collect information that allows the origin of the product to be assessed.
The regulation is particularly relevant for companies importing, exporting, producing, processing or trading products that fall within its scope. As implementation approaches, businesses are increasingly required to integrate EUDR requirements into procurement, supplier management, compliance, customs and supply-chain processes.
Which Commodities and Products Are Covered by EUDR?
EUDR covers seven commodities considered particularly associated with global deforestation:- cattle
- cocoa
- coffee
- oil palm
- rubber
- soy
- wood
The regulation also covers a range of products made from or containing these commodities. However, determining whether a particular product falls within the scope of EUDR is not simply a matter of checking whether its commercial description contains one of these commodities.
The regulation uses specific product classifications, including the relevant Harmonised System (HS) and Combined Nomenclature (CN) codes listed in its annexes. This means that companies should examine the actual classification of their products rather than relying solely on general product names. The European Commission has also updated the product scope and supporting implementation tools during 2026. Companies preparing for EUDR should therefore work with the current legal text and Commission guidance rather than relying exclusively on older compliance checklists or articles published before the latest amendments.
For businesses with large product portfolios, reviewing HS/CN classifications can therefore be an important first step in determining which products require further EUDR analysis.
What Does EUDR Compliance Require?
At its core, EUDR compliance is based on a due diligence process.The regulation identifies three principal elements:
- Information collection
- Risk assessment
- Risk mitigation where necessary
Companies must establish appropriate procedures to collect and maintain the information required by the regulation. They must then assess whether the relevant products present a risk of non-compliance and, where a risk exists, take appropriate mitigation measures.
The European Commission specifically notes that EUDR due diligence is not intended to be a simple fixed checklist. The process should reflect the circumstances and complexity of the particular supply chain, while ultimately allowing the operator to establish that there is no or only negligible risk of non-compliance.
This distinction is important.
A company may have a large collection of supplier documents and still need to assess whether those documents and other available information provide a sufficient basis for concluding that the product complies with EUDR.
1. Information Collection
The first stage involves collecting information, documents and data relating to the relevant product and its origin.
Depending on the product and supply chain, this can include:- product description;
- quantity;
- country of production;
- supplier information;
- information about downstream recipients;
- production location;
- geolocation data;
- evidence relating to legality of production;
- information demonstrating that the product is deforestation-free.
Operators are required to retain the relevant information and evidence for the period specified by the regulation.
2. Risk Assessment
The collected information must then be analysed to determine whether there is a risk that the product does not comply with EUDR.
Risk assessment can involve consideration of factors such as:- the risk classification of the country of production;
- the presence and characteristics of forests in the relevant area;
- the prevalence of deforestation or forest degradation;
- the complexity of the supply chain;
- the reliability and completeness of available information;
- the risk of mixing products from different origins;
- relevant evidence concerning the production location;
- legality-related risks in the country of production.
The regulation requires operators to analyse the information available to them rather than simply collecting documents and storing them.
3. Risk Mitigation
If the risk assessment identifies more than a negligible risk, the operator must take appropriate risk mitigation measures. These measures may include obtaining additional information or documentation, conducting additional verification, working with suppliers to resolve information gaps or taking other appropriate steps depending on the circumstances of the supply chain.
The objective is to reach a level where the risk of non-compliance is no more than negligible before the relevant product is placed on the EU market or exported.
EUDR Geolocation Requirements Geolocation is one of the most distinctive requirements introduced by EUDR.
For relevant commodities, companies must obtain the geographic location of the plots of land where the commodities were produced. Where a product contains commodities produced on multiple plots, the relevant locations need to be identified accordingly.
For cattle-related products, the geolocation requirement applies to the establishments where the cattle were kept. For other relevant commodities, the information generally relates to the plots of land where production took place.
This requirement creates a direct connection between a product entering the EU supply chain and the physical location where the underlying commodity was produced.
For example, knowing that coffee was purchased from a company in a particular country does not necessarily provide the same information as knowing the specific production locations from which the coffee originated.
Geolocation can therefore become an important part of EUDR supply-chain traceability.
The EUDR Information System allows operators to provide location information through coordinates and geographical areas. The system also supports bulk uploads, including GeoJSON files, for companies dealing with multiple locations.
For businesses managing numerous suppliers or production sites, collecting, organising and maintaining accurate geolocation data can become a significant operational task.
EUDR Due Diligence Statement.
A Due Diligence Statement, commonly referred to as a DDS, is an important part of the EUDR compliance process. Before relevant products are placed on the EU market or exported, the required due diligence must have been completed and the relevant Due Diligence Statement or applicable simplified declaration submitted through the EUDR Information System.
The DDS contains information connected with the operator and the relevant product, including information such as:
- product classification;
- product description;
- quantity;
- country of production;
- geolocation of relevant production areas;
- relevant due diligence information;
- reference information where applicable.
The statement confirms that the required due diligence has been carried out and that no or only negligible risk of non-compliance has been identified. This makes the DDS more than an administrative form.
It represents the formal conclusion of the due diligence process.
For that reason, companies should treat the preparation of a DDS as the final stage of an underlying information and risk-assessment process rather than as a substitute for that process.
EUDR and Supply Chain Due Diligence
One of the main challenges associated with EUDR is supply-chain complexity.A company may purchase a finished product from one supplier while the relevant commodity may have originated much further upstream. A simplified supply chain could look like this:
Producer → Local trader → Processor → Exporter → EU importer → Distributor
In more complex cases, there may be several processors, traders or intermediaries between the original producer and the company placing the product on the EU market.
EUDR compliance therefore requires businesses to understand the relevant information behind the immediate commercial transaction. The precise legal obligations depend on the role of the company within the supply chain and on whether the relevant product has already been subject to due diligence.
The 2025 amendments simplified certain obligations for downstream operators and traders. Under the current framework, the primary due diligence responsibility generally sits with the operator first placing the relevant product on the EU market or exporting it, while downstream obligations differ depending on the company's size and role.
This makes it particularly important for businesses to understand their exact regulatory role rather than applying a generic EUDR checklist to every company in the supply chain.
EUDR Risk Assessment
Risk assessment is a central part of EUDR compliance.
The purpose is to determine whether the information collected provides sufficient grounds to conclude that the relevant product presents no more than a negligible risk of non-compliance.
The assessment may consider several categories of risk.
Country and regional risk.
The country or region where a commodity was produced can influence the level of risk associated with a supply chain. Companies may need to consider the relevant EUDR country benchmarking status and other characteristics of the production environment. Deforestation and forest degradation risk
The production location is central to determining whether the relevant commodity was produced on land associated with prohibited deforestation or forest degradation.
This makes the relationship between geolocation and land-use information particularly important.
Supply-chain complexity.
The more intermediaries and production stages a supply chain contains, the more difficult it can become to maintain complete and reliable traceability. Complex supply chains may also create additional opportunities for information gaps, mixing or inconsistent documentation.
Reliability of information.
Risk assessment should also consider whether the available information is sufficiently reliable and verifiable. A complete-looking document package does not automatically eliminate the need to assess the quality and consistency of the information it contains.
Legality risk.
EUDR also requires relevant commodities to have been produced in accordance with applicable legislation in the country of production. Depending on the commodity and jurisdiction, this can involve areas such as land-use rights, environmental protection, labour-related requirements and other applicable legal rules.
How Companies Can Prepare for EUDR Compliance
Businesses that may be affected by EUDR can begin preparation by establishing a structured internal process.A practical starting point can include the following steps.
1. Identify products within the EUDR scope
Review the company's product portfolio and determine which products correspond to the relevant commodities and classifications listed in the regulation.
2. Review HS/CN classifications
Check the applicable customs and product classifications rather than relying only on commercial product descriptions.
3. Map relevant suppliers
Identify the companies and entities involved in the relevant supply chain and determine which information is available from each supplier.
4. Identify production origins
Determine where the underlying commodities were actually produced. This may require moving beyond the immediate supplier and identifying relevant production locations further upstream.
5. Collect geolocation data
Collect the coordinates or relevant geographical information required under EUDR and organise it in a format suitable for the company's due diligence process.
6. Collect supporting documentation
Gather relevant information concerning the product, origin, supplier, production and legality of the relevant commodity.
7. Establish a due diligence process
Create internal procedures defining:
- who collects information;
- who reviews supplier data;
- who performs risk assessments;
- how missing information is handled;
- how risk mitigation is documented;
- who is responsible for the DDS process.
8. Assess risks
Analyse the available information and determine whether there is a risk of non-compliance.
9. Mitigate identified risks
Where the available evidence does not support a negligible-risk conclusion, take appropriate measures before placing the relevant product on the EU market or exporting it.
10. Maintain records and review the system
EUDR requires operators to establish and maintain a due diligence system and review it regularly. The regulation provides for record-keeping requirements and requires relevant due diligence systems to be kept up to date.
For companies with complex supply chains, this process should be integrated into procurement and supplier-management procedures rather than treated as a one-time compliance project.
Common EUDR Compliance Challenges
Although the basic structure of EUDR due diligence is relatively clear, implementation can be difficult in practice.Incomplete supplier information
Suppliers may not initially provide all information required for EUDR due diligence. This can be particularly challenging when buyers have limited visibility into upstream producers.
Incorrect or incomplete geolocation - Production coordinates may be missing, incomplete or inconsistent with other information available about the production site. Because geolocation is a core EUDR requirement, resolving such gaps can be important before a product can be considered compliant.
Fragmented supply chains - Companies sourcing from multiple traders, processors or producers may have difficulty maintaining a complete picture of the supply chain.
Lack of traceability - where commodities are mixed or consolidated during processing and trading, businesses may need additional information to establish the relationship between the final product and its relevant production origins.
Documentation gaps - documents relating to production, land use or legality may be incomplete, outdated or difficult to connect to the specific product being assessed.
Changing supplier structures - suppliers, traders and production arrangements can change over time. A compliance process that works for one sourcing arrangement may therefore require updates when the supply chain changes.
For this reason, EUDR compliance should generally be treated as an ongoing due diligence process rather than a one-time documentation exercise.
When Does EUDR Apply?
The implementation timeline has been revised since the regulation was originally adopted.
As of 2026, EUDR is scheduled to apply from 30 December 2026 to large and medium-sized operators and to micro and small operators already covered by the EU Timber Regulation.
For most other micro and small operators, the application date is 30 June 2027.
The European Commission has also introduced updates to the EUDR product scope, Information System and implementation guidance during 2026. Companies preparing for compliance should therefore use the current version of the regulation, Commission guidance and Information System documentation when establishing their internal procedures.
Why EUDR Compliance Requires More Than Documentation
One of the most important aspects of EUDR is the connection between documentation, traceability and actual production conditions.
A supplier declaration can provide useful information, but EUDR due diligence ultimately requires an operator to establish that the relevant product presents no more than a negligible risk of non-compliance.This means that companies may need to combine different types of information:
Product information + supplier information + production location + geolocation + legality evidence + risk assessment
The exact process will depend on the product, country, supplier structure and role of the company within the supply chain. For some businesses, EUDR preparation may therefore involve procurement and supplier questionnaires. For others, especially those dealing with complex international supply chains, it may require more extensive supply-chain mapping, document analysis, geolocation review and additional verification.
Conclusion
EUDR compliance introduces a new level of traceability and due diligence for companies dealing with commodities and products associated with deforestation. The basic compliance process consists of collecting the required information, assessing the associated risks and taking appropriate mitigation measures where necessary. Geolocation, product classification, supplier information, production origin and evidence of legal production all form part of this process. For companies preparing for EUDR, the most practical starting point is to understand which products are in scope, identify the company's role in the supply chain, map relevant suppliers and production locations, establish a reliable information-collection process and develop a structured approach to risk assessment.
EUDR compliance is not simply a documentation exercise. Companies need reliable information about products, suppliers, production locations and supply chains in order to make informed due diligence decisions.
BravaBridge Intelligence supports businesses with EUDR due diligence, supplier research, geolocation verification and supply-chain intelligence. Our approach combines business research, open-source intelligence and supply-chain analysis to help companies understand the information behind their EUDR compliance process.
Thank you for your attention.
The Bravabridge Team
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