EU Deforestation Regulation (EUDR) – Strengthening Sustainable Supply Chains

🧾 Introduction
The EU Deforestation Regulation (EUDR) (EU) 2023/1115 ensures that commodities linked to deforestation or forest degradation are excluded from the European market.

It became law on 29 June 2023 and applies from 31 December 2024.

Under the regulation, operators and traders placing or making available certain commodities and products must prove that their goods are deforestation‑free and legally produced.

By enforcing traceability and due diligence, the EUDR supports sustainable sourcing and aligns EU consumption with global environmental protection goals.

⚙️ Scope and Key Principles
The EUDR applies to seven relevant commodities:
• Cattle
• Cocoa
• Coffee
• Oil palm
• Rubber
• Soya
• Wood

It also covers products that contain, have been fed with, or have been made using these commodities (as listed in Annex I).

Products may only be placed on the market or exported when they:

• Are deforestation‑free (produced on land not subject to deforestation after 31 December 2020).
• Comply with relevant legislation in the country of production.
• Are covered by a due diligence statement proving compliance.

The EUDR applies to all companies marketing such goods, regardless of where they are established.

👥 Who Is in Scope
Roles and obligations depend on each company’s position in the supply chain.

🏭 Operators

Operators place relevant products on the EU market for the first time or export them outside the Union.

They are fully responsible for conducting due diligence and submitting due diligence statements.

💼 Traders

Traders are entities that make such products available further downstream.

They must maintain records, assist authorities, and share product compliance evidence when requested.

Simplified due diligence exists for small and medium‑sized enterprises (SMEs) under certain conditions, but responsibility for overall compliance remains.

🧾 Core Obligations of Operators

1. Exercising Due Diligence

Before placing or exporting products, operators must ensure and document that:
• Products are deforestation‑free.
• Commodities were produced legally.
• All plots of land are identified and traceable.

2. Due Diligence Statement

Operators must electronically submit a due diligence statement through the EU information system prior to product placement or export.
The declaration confirms that all due diligence steps have been taken and that only negligible risk remains.

3. Record Keeping and Reporting

Operators must:
• Retain due diligence documentation for at least five years.
• Notify competent authorities if new risk information arises.
• Provide requested data and cooperate during inspections.

4. Supply Chain Communication

Operators must pass necessary due diligence information and reference numbers to downstream traders, maintaining full supply chain transparency.

🏢 SME and Non‑SME Obligations

🧩 SME Operators

SME operators may rely on an existing due diligence statement prepared by another operator but must reference its official number.
If segments of their supply chain are not already covered, they must perform due diligence for those elements.

🧩 Non‑SME Operators

Non‑SME operators must verify that any referenced due diligence statement has been properly prepared.
They remain legally responsible for ensuring overall compliance.

🧾 Traders

All traders must:
• Assist authorities in compliance checks.
• Keep product and supplier records for five years.
Non‑SME traders are subject to the same full due diligence obligations as operators.

⚙️ Due Diligence Process

Due diligence under the EUDR is structured into three distinct stages:

1. Information Collection

Operators must gather and keep:
• Product description, trade name, and HS code.
• Quantity of each relevant product.
• Country of production and precise geolocation (latitude/longitude).
• Supplier and customer details.
• Evidence showing the commodities are deforestation‑free and produced legally.

2. Risk Assessment

Operators assess risks of non‑compliance by examining:
• Deforestation rates or forest‑degradation levels in production areas.
• Supply chain complexity.
• Substantiated third‑party concerns or alerts.

The assessment must be documented, reviewed annually, and made available to authorities on request.

3. Risk Mitigation

If non‑negligible risk remains, operators must take mitigation steps such as:
• Requesting additional proofs or documentation.
• Performing independent audits of suppliers.
• Introducing stricter internal controls or a compliance officer role.

📜 Content of the Due Diligence Statement

Each statement must include:
• Operator’s name, address, and EORI number.
• Description, HS code, and quantity of the product.
• Country of production and all relevant geolocation coordinates.
• References to any previously issued due diligence statement.
• A signed confirmation declaring that due diligence has been completed and that negligible risk has been identified.

Statements are submitted electronically before any product enters or exits the market and must be retained for five years.

🗺️ Geolocation and Digital Submissions

The EUDR requires accurate geolocation data for each production plot, recorded to at least six decimal places.
Plots larger than four hectares must be reported using polygons describing boundaries.

Data is prepared in GEOJSON and XML formats and submitted via the Commission’s online platform.

Each file must include operator, product, and location details confirming regulatory compliance.

🛡️ Enforcement and Record Keeping

Competent authorities will monitor compliance through inspections and document checks.

Operators and traders must:
• Provide access to records and premises when requested.
• Maintain all due diligence statements and evidence for five years.
• Inform authorities promptly of any potential non‑compliance.

Penalties for violations will be proportionate but dissuasive, ensuring consistent enforcement across Member States.

✅ Key Takeaways

• The EUDR applies from 31 December 2024 to seven key commodities and their derived products.
• Operators must prepare due diligence statements and maintain evidence of deforestation‑free origin.
• Accurate geolocation data and transparent risk assessments are mandatory for all supply chains.
• Early preparation ensures continued EU market access and protection against enforcement risks.

🤝 How ComplyMarket Supports EUDR Compliance
Achieving EUDR compliance demands robust data management, traceable sourcing information, and seamless digital reporting.

ComplyMarket supports organizations by:
• Simplifying preparation of due diligence statements and digital submissions.
• Generating compliant GEOJSON location files automatically through its platform.
• Providing structured risk‑assessment and mitigation workflows.
• Helping operators and traders meet all requirements before the 31 December 2024 deadline.

With the right compliance infrastructure in place, companies can demonstrate sustainable sourcing, ensure uninterrupted market access, and contribute to global deforestation‑reduction efforts — supported by ComplyMarket.