Background
What is the EUDR — and why does it matter for your supply chain?
The EU Deforestation Regulation (EUDR) requires companies trading in cattle, cocoa, coffee, oil palm, rubber, soy, wood, and derived products to implement due diligence measures ensuring their supply chains are free from deforestation, forest degradation, and local law violations since 31 December 2020.
Starting 30 December 2025 (or 30 June 2026 for smaller companies), only products classified as "deforestation-free" and compliant with local laws may be imported or exported to the EU. Companies within its scope must identify, prevent, and mitigate respective risks across their operations and supply chains.
The core challenge: EUDR requires plot-level geolocation data linking every commodity to the specific piece of land where it was produced. Most supply chains do not have this data structured — and collecting it from upstream suppliers across multiple tiers is the make-or-break operational challenge.
This guide focuses on the practical supply chain implications: what data you need from your suppliers, how to collect geolocation coordinates, how to structure your due diligence process, and how to submit statements to the EU Information System.
Key dates
EUDR implementation timeline
Jun 2023
Regulation entered into force
EUDR published in the EU Official Journal. 18-month implementation period for operators begins.
In forceNow
Supplier outreach & data collection
Map your supply chains, identify commodity origins, collect geolocation data from suppliers.
Action requiredDec 2025
Enforcement begins — large operators
Due diligence statements required for all covered products placed on or exported from the EU market.
UpcomingJun 2026
SME enforcement begins
Small and medium-sized enterprises must comply with full due diligence obligations.
SMEs2028+
Scope expansion review
Commission reviews whether to add further commodities, ecosystems (e.g. other wooded land), and financial institutions.
FutureQuestion vault
Real questions. Expert answers.
Questions submitted by procurement, sustainability and operations professionals — curated and answered by our regulatory team. Submit yours below and get notified when it's published.
42
Which commodities and products are covered by the EUDR?
TH
Thomas H. · Procurement Director, Germany · 2 weeks ago∨
✦ Expert answer
Seven commodity groups are in scope: cattle, cocoa, coffee, oil palm, rubber, soy, and wood — plus their derived products. This includes a wide range of downstream goods: leather, chocolate, furniture, paper, tyres, cosmetics containing palm oil, and many more.
The full list of covered products is defined in Annex I of the regulation, mapped to CN (Combined Nomenclature) codes. If your product contains, was fed with, or was made using any of these commodities, it falls within scope. The key obligation: you must prove the commodity was produced on land that was not deforested after 31 December 2020.
The full list of covered products is defined in Annex I of the regulation, mapped to CN (Combined Nomenclature) codes. If your product contains, was fed with, or was made using any of these commodities, it falls within scope. The key obligation: you must prove the commodity was produced on land that was not deforested after 31 December 2020.
38
What geolocation data do we need to collect from suppliers, and in what format?
JL
Julia L. · Supply Chain Manager, Austria · 1 week ago∨
✦ Expert answer
You need the geographical coordinates of the plots of land where the commodity was produced. For plots under 4 hectares, a single latitude/longitude point is sufficient. For larger plots, you need a polygon — a set of coordinates outlining the boundary of the production area.
Coordinates must be in decimal degrees format (e.g. 51.5074, -0.1278). This data must be traceable back to the specific production plot — not just a region or country. For supply chains with multiple tiers, each operator must pass geolocation data upstream. If your Tier 1 supplier sources from a processor who sources from farms, the farm-level coordinates must ultimately reach you.
Coordinates must be in decimal degrees format (e.g. 51.5074, -0.1278). This data must be traceable back to the specific production plot — not just a region or country. For supply chains with multiple tiers, each operator must pass geolocation data upstream. If your Tier 1 supplier sources from a processor who sources from farms, the farm-level coordinates must ultimately reach you.
31
Does the EUDR apply to SMEs, or only to large companies?
RB
Ralf B. · CEO, Germany · 3 weeks ago∨
✦ Expert answer
EUDR applies to all companies placing covered products on the EU market, regardless of size. However, SMEs classified as "small and medium-sized enterprises" under EU definitions get a delayed start date — 30 June 2026 instead of 30 December 2025 for larger operators.
The obligations are the same: due diligence, geolocation data, risk assessment, and a due diligence statement submitted to the EU Information System. There is no exemption from the core requirements — only a timing difference. If you trade in wood, coffee, cocoa, soy, palm oil, rubber, or cattle products in the EU, you are in scope.
The obligations are the same: due diligence, geolocation data, risk assessment, and a due diligence statement submitted to the EU Information System. There is no exemption from the core requirements — only a timing difference. If you trade in wood, coffee, cocoa, soy, palm oil, rubber, or cattle products in the EU, you are in scope.
27
How do we get geolocation data from Tier 2/3 suppliers who don’t have GPS coordinates?
SP
Sandra P. · Sustainability Manager, Italy · 5 days ago∨
✦ Expert answer
This is the single biggest operational challenge of EUDR. Many upstream suppliers — especially smallholders and cooperatives in producing countries — do not have digital coordinates of their production plots.
Practical approaches: (1) Send structured questionnaires asking for coordinates — even approximate ones can be validated against satellite imagery; (2) Use satellite-based tools to help suppliers identify their plots on a map and extract coordinates; (3) Work with cooperatives and industry bodies who may already have plot-level mapping; (4) For wood, sawmill intake records often include forest concession data that can be geocoded.
The regulation does not accept "we couldn't get the data" as an excuse. If you cannot obtain geolocation data for a supply chain, you cannot place that product on the EU market.
Practical approaches: (1) Send structured questionnaires asking for coordinates — even approximate ones can be validated against satellite imagery; (2) Use satellite-based tools to help suppliers identify their plots on a map and extract coordinates; (3) Work with cooperatives and industry bodies who may already have plot-level mapping; (4) For wood, sawmill intake records often include forest concession data that can be geocoded.
The regulation does not accept "we couldn't get the data" as an excuse. If you cannot obtain geolocation data for a supply chain, you cannot place that product on the EU market.
22
What is the EU Information System, and do we need to submit data there?
PK
Peter K. · Compliance Officer, Poland · 1 week ago∨
✦ Expert answer
Yes. Before placing a covered product on the EU market (or exporting it), you must submit a due diligence statement to the EU Information System. This is a digital portal where you declare that your product is deforestation-free and compliant with local laws.
The statement includes: your company details, product description, commodity type, country of production, geolocation data, and a declaration that due diligence was performed. You receive a reference number that must accompany the product through the supply chain. Downstream operators and traders need this reference number from their suppliers.
The system is operated by the European Commission. Access will be available through a web portal, and large operators will likely be able to submit via API. The exact technical specifications are still being finalized.
The statement includes: your company details, product description, commodity type, country of production, geolocation data, and a declaration that due diligence was performed. You receive a reference number that must accompany the product through the supply chain. Downstream operators and traders need this reference number from their suppliers.
The system is operated by the European Commission. Access will be available through a web portal, and large operators will likely be able to submit via API. The exact technical specifications are still being finalized.
18
What happens if we can’t prove a product is deforestation-free? What are the penalties?
AV
Anna V. · Head of Legal, Czech Republic · 3 days ago∨
✦ Expert answer
Penalties are severe and designed to deter non-compliance. National authorities can impose fines of up to 4% of annual EU turnover. Other consequences include: product seizures and confiscation, exclusion from public procurement contracts, temporary bans on placing products on the EU market, and for repeat offenders — permanent trade bans.
Authorities will conduct both routine and surprise inspections, including physical checks at borders. They will also use satellite monitoring and risk-based targeting to identify suspicious shipments. Private parties (including NGOs) can bring legal action if they believe violations are being overlooked.
Authorities will conduct both routine and surprise inspections, including physical checks at borders. They will also use satellite monitoring and risk-based targeting to identify suspicious shipments. Private parties (including NGOs) can bring legal action if they believe violations are being overlooked.
14
Do we need to collect geolocation data for wood sourced within the EU (e.g. from European forests)?
HM
Henrik M. · Timber Buyer, Sweden · 2 weeks ago∨
✦ Expert answer
Yes — geolocation requirements apply regardless of the country of origin. Whether your wood comes from Brazil or Sweden, you must have coordinates for the forest plot where it was harvested. The regulation does not distinguish between EU and non-EU sourcing for this requirement.
However, the risk level differs. The Commission will publish a country benchmarking system classifying countries (or regions within countries) as low, standard, or high risk. EU countries are likely to be classified as low risk, which means simplified due diligence — but the geolocation data requirement still applies. You just may not need as deep a risk assessment.
However, the risk level differs. The Commission will publish a country benchmarking system classifying countries (or regions within countries) as low, standard, or high risk. EU countries are likely to be classified as low risk, which means simplified due diligence — but the geolocation data requirement still applies. You just may not need as deep a risk assessment.
8
Can we reuse EUDR due diligence data for CSRD Scope 3 reporting and customer sustainability questionnaires?
MK
Maria K. · ESG Manager, Netherlands · 1 day ago∨
Coming soon
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