From the end of 2025, the EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) will govern businesses placing products such as beef, wood, cocoa, coffee, palm oil, soya or rubber on the EU market or exporting them from the EU. The key requirement? You must be able to show that each product is free from deforestation after 31 December 2020 and complies with the laws of its country of origin. That calls for thorough supply chain due diligence, ongoing risk management and proper documentation.
Step 1. Understand your role, your supply chain and your products
What the rules ask of you depends very much on where you sit in the chain (operator, trader, downstream operator) and on the type of product. So start by establishing:
- Are you an operator (first to place goods on the EU market, or an exporter) or a trader (reselling within the EU without processing)?
- Which products (“commodities and derived products”) fall within the scope of the EUDR?
- How does your supply chain run, from source to finished product? Without these basics, no reliable risk profile is possible.
Step 2. Map every relevant product, supplier and country of origin
For each product and supplier, record:
- Origin (country/region)
- The producers and intermediaries involved
- HS codes (customs codes, see Annex I to the EUDR)
- Possible low-risk countries that qualify for the simplified procedure. This mapping is essential for traceability, for assessing risk and for closing any gaps in compliance. Screening suppliers by role (primary operator, micro-business or SME, downstream actor) makes clear who has to carry out full due diligence and who falls under simplified obligations.
Step 3. Collect and organise the required data and records
Bring together all the information asked for:
- GPS locations and polygons of the plots of origin
- Production dates (after 31 December 2020)
- Legal documents (land title, permits, labour, environmental and indigenous rights)
- Evidence that the product is deforestation-free (satellite data, land-use history and so on)
- Details of suppliers and customers. Make sure all of this is clear, verifiable and accessible for five years; keeping it digitally is by far the better option.
Step 4. Bring risk assessment and risk mitigation together into one continuous process
Bring EUDR risk assessment (Article 10) and risk mitigation (Article 11) together in a continuous workflow:
- Assess risk at country level (deforestation trends, legal enforcement), supply chain level (number of links, transparency) and plot or supplier level (documents, conduct).
- If you identify more than a negligible risk, you must take steps to reduce it: gather further evidence, engage suppliers, carry out audits if needed or rule out supply channels. Build risk controls into supplier management and run independent checks where necessary.
Step 5. Draw up the EUDR due diligence statement (DDS) where required and keep full records
A DDS must be drawn up in good time for every consignment of relevant products and filed digitally through the EU's TRACES system. In it, the operator formally confirms that the product meets the EUDR requirements.
Make sure your record-keeping system also:
- Links every DDS (with its unique reference) to the consignment and the internal file
- Records reference numbers for later audits
- Lets downstream parties pass on and retain the right documentation
Step 6. Put ongoing monitoring, updates and governance in place
Compliance does not end with a single DDS:
- Trace every new batch of products back to source before you sell or export
- Keep track of changes in country risk and legal requirements
- Keep all files and assessments for five years
- Be ready for inspection by the authorities, with documentation available at short notice
- If you are a large or medium-sized business, publish a compliance summary each year
Finally: make smart use of technology and due diligence tools
Managing EUDR compliance by hand is risky and inefficient. Digital due diligence tools bring your data together, automate risk assessment and make filing and monitoring scalable, which is essential if compliance is to hold up and you want to respond straight away when the law or the market shifts.
Further practical and governance tips
- Start early: lead times at suppliers and in IT can create bottlenecks.
- Use standard questionnaires and documents when onboarding suppliers.
- Put in place a legally validated due diligence system, with authorisation rules and audit logging.
- Set out in your supplier contracts that they will cooperate fully on EUDR matters.
Who is this guide for?
This guide is for businesses dealing with the EUDR at an operational or strategic level that need a structured, legally sound approach to risk management, governance and sustainability.
Key points and next steps
- Sharpen how you identify your role, your chain and your products
- Digitise data capture and risk assessment
- Set up a single governance process for EUDR compliance
- Review and update your approach as the rules change
- Consider bringing in external legal experts for a while to validate the system or get it up and running quickly
Want to know more, or talk it through?
Neem contact op met Dries Beljon (dr***@*********rs.nl) en/of Mathijs Arts (ma*****@*********rs.nl) voor advies of een quick scan van uw EUDR-aanpak. Voor uitgebreide modeldocumenten, checklists of compliance-audits, bieden wij uiteraard ondersteuning op maat.