What is the EUDR and why it changes supply chain management

The EUDR, short for European Union Deforestation Regulation, is the EU regulation governing the placing on the EU market and export of certain commodities and products linked to the risk of deforestation and forest degradation. The main legal reference is Regulation (EU) 2023/1115, later amended by Regulation (EU) 2025/2650.

For companies, the EUDR introduces a clear operational requirement: before placing, making available or exporting relevant products, a company must be able to demonstrate that they are deforestation-free, compliant with the legislation of the country of production and covered by an EUDR due diligence statement, where required.

This changes the way supply chains need to be documented. Compliance can no longer rely on generic supplier declarations; it requires the ability to connect product, commodity, supplier, country of production, geolocation and risk assessment. As Alessandro Nora of Metrikflow put it during the webinar “EUDR 2026: latest updates and compliance readiness”, compliance is moving “from mere documentation to verifiable traceability”.

The impact involves procurement, logistics, quality, compliance, sustainability, legal and operations teams. Each function holds part of the information required, but EUDR compliance requires these data points to be reconcilable, up to date and available before the product is placed on the EU market or exported.

Which commodities and products fall under the EUDR

The EUDR covers seven main commodities: cattle, cocoa, coffee, palm oil, rubber, soy and wood. Its scope also includes many derived products listed in Annex I of the regulation and identified through customs codes. This point is essential because EUDR applicability does not depend on the commercial category used internally by the company, but on the customs code and the link with one of the covered commodities.

The EUDR can therefore affect a wide range of sectors, including food, furniture, packaging, cosmetics, automotive, fashion, retail, manufacturing and international trade. A company may fall within scope because of products containing cocoa, coffee, leather, natural rubber, paper, wood, beef, soy or palm oil derivatives. Components, semi-finished goods, packaging materials or processed products may also trigger obligations if they fall under the codes listed in the regulation.

The first useful analysis is a classification of the product portfolio. For each potentially relevant item, the company should verify the customs code, associated commodity, country of production, supplier and role in the commercial flow.

The key issue is not only whether a supplier handles EUDR commodities. Companies need to understand for which products, volumes, batches and origins evidence must be collected. This reduces the risk of sending overly generic requests to the supplier base and helps focus resources on the flows that are actually exposed.

Which companies are involved: operators, traders and roles in the value chain

Once a company has defined which products fall under the EUDR, it needs to understand its role in the value chain. The regulation distinguishes between operators and traders. In general terms, the operator is the entity that places a relevant product on the EU market for the first time or exports it from the Union. The trader is the entity that makes a product already placed on the market available.

This distinction matters because many companies do not directly produce the commodities covered by the EUDR, but may still fall under its obligations. A coffee importer, a food manufacturer using cocoa, a brand selling leather goods or a company trading wood products must verify not only what it purchases, but also how that product enters the EU market, who holds information about its origin and which entity must submit or retain the due diligence statement.

Role mapping should follow actual flows, not the organisational chart. In multinational groups, one entity may purchase, another may process, another may export and another may sell on the European market. In these cases, EUDR governance should clarify who collects data, who assesses risk, who manages the statement, who stores evidence and who responds in the event of an inspection.

This stage connects the product scope with corporate responsibility. Without this reading, there is a risk of treating the EUDR as an activity owned only by the sustainability team, while in practice it affects procurement, customs, logistics, legal, quality and supply chain management.

EUDR 2026 and 2027 deadlines: what changes with the postponement

The latest EUDR postponement changed the original application timeline. Following the updates introduced by Regulation (EU) 2025/2650, the obligations apply from 30 December 2026 for medium and large operators and traders, and from 30 June 2027 for micro and small enterprises, according to the conditions set out in the updated legal text.

The EUDR postponement does not change the structure of the obligations; it changes the date by which companies will need to demonstrate compliance. The European Commission has also published an EUDR implementation FAQ, updated on 4 May 2026, clarifying practical aspects related to traceability, geolocation, due diligence statements, roles along the value chain and use of the EU information system.

To interpret the deadline correctly, companies should connect it to their purchasing and sourcing cycles. A commodity purchased today may enter production, processing or distribution months later. Similarly, a non-EU supplier may need time to collect geographic coordinates, information about upstream producers and supporting documentation.

2026 is not a postponement window; it is a preparation window.

The regulatory deadline should therefore be translated into an internal roadmap, with responsibilities, data sources, control points and validation criteria defined before the goods reach the point of sale, import or export.

EUDR due diligence: data, risk and the due diligence statement

EUDR due diligence is the core of the regulation. The process is based on three connected steps: information collection, risk assessment and risk mitigation, where needed. At the end of this process, if the risk is found to be negligible or non-existent, the operator can manage the EUDR due diligence statement, often referred to as the DDS.

The first layer concerns data. For each relevant product, companies need information on quantity, country of production, supplier, operators involved, commercial documents, batches and geolocation of the plots of land where the commodities were produced. Geolocation is one of the most sensitive elements, because it is not enough to indicate a generic country of origin: the company must be able to connect the goods to specific production areas, in line with the requirements of the regulation.

The second layer concerns data quality. Information must be complete, consistent with the product, up to date and traceable to a verifiable source. A generic supplier declaration is not sufficient if it does not allow the company to connect the batch, commodity, production area and risk assessment. Technology can support the collection, organisation and control of information, but it does not replace technical evaluation. Human judgement remains essential because responsibility for due diligence remains with the operator.

The third layer concerns risk assessment and mitigation. The company must determine whether the risk that the product is non-compliant is non-existent, negligible or requires mitigation. This analysis may consider the country and area of origin, the risk associated with the commodity, supply chain complexity, the presence of intermediaries, supplier reliability, the quality of geographic coordinates and the consistency between commercial documents and declared information. If the risk is not negligible, additional evidence, document checks, geospatial tools, third-party verification, supplier review or changes to purchasing conditions may be required.

The EUDR due diligence statement should therefore not be treated as an isolated form. It is the output of a documented process. It must be based on collected data, completed checks, assessed risk and tracked mitigation measures. This affects business processes: EUDR information must be available before the product is placed on the market or exported, not reconstructed only in the event of an audit.

To make the process measurable, companies can define specific EUDR KPIs: percentage of products classified by customs code, share of volumes covered by geolocation, number of suppliers with complete data, rate of incomplete documentation, number of non-negligible risk cases, open mitigation actions and average time to close checks. These indicators help identify where the supply chain is most exposed and which information is still missing to reach compliance.

EUDR supply chain: suppliers, ESG data and business processes

Once data, risk and the due diligence statement are clear, the issue becomes organisational: how to make the process manageable across the supply chain. Supplier engagement is one of the most delicate aspects of EUDR compliance because not all actors have the same level of exposure, digital maturity or ability to provide data in the required format.

The first step is to segment suppliers. A supplier delivering non-relevant products requires limited control, while a strategic supplier of cocoa, coffee, leather, natural rubber, wood, soy or palm oil derivatives requires a more detailed assessment, especially if it operates in fragmented supply chains or through multiple intermediaries. This segmentation allows companies to define different levels of request, avoiding the same documentation burden across the entire supplier base.

Supplier engagement cannot be reduced to sending a standard questionnaire. In many supply chains, the data may not yet exist in the required format, and the supplier relationship may not have been built to support this type of exchange. Data collection should therefore be supported by clear instructions, training, revised templates, updated contractual clauses and defined responsibilities across the value chain.

In more fragmented supply chains, especially where small producers or several layers of intermediaries are involved, it may be necessary to work through cooperatives, producer groups, qualified traders or local partners. This approach can improve data quality without multiplying unmanageable requests to individual upstream actors.

The EUDR should then be integrated into existing processes. Companies that have already started rating, audit or ESG assessment activities can connect the regulation to their supplier assessment workflows, avoiding a separate and disconnected process. Similarly, an ESG platform can help centralise data, documents, responsibilities and progress tracking.

The connection with other ESG processes is also relevant from a data perspective. Information on origin, volumes, suppliers and supply chain structure can support the calculation of a company’s carbon footprint, the analysis of Scope 3 emissions and Life Cycle Assessment approaches. For companies subject to sustainability reporting requirements, the same data can contribute to the sustainability report, supply chain risk management and the preparation of more robust disclosures.

The connection with European regulations such as CSRD and CBAM should be read from this perspective: different obligations, but the same underlying need for traceable, verifiable and up-to-date data across the value chain.

Conclusion: from EUDR compliance to supply chain risk management

The EUDR requires companies to make their supply chains more traceable, documentable and controllable. The postponement to 2026-2027 gives companies time to structure stronger processes, but the value of this work goes beyond regulatory compliance: well-managed EUDR data reduces the risk of operational blocks, incomplete supplier requests, documentation inconsistencies and difficulties in the event of an inspection.

The priorities are clear: define the scope of products subject to the EUDR, verify roles and responsibilities, collect origin and geolocation data, set risk criteria, structure the EUDR due diligence statement and integrate information into business workflows.

To explore the official regulatory framework, companies can also consult the European Commission page on deforestation regulation implementation and the updated EUDR FAQ. The decisive part remains internal: building a system that makes EUDR compliance measurable, updatable and ready for potential checks.