When world leaders met in early November 2025 in Belém, Brazil, at the edge of the Amazon rainforest, the choice of location was symbolic. Bringing COP30 into the heart of a region shaped by deforestation highlighted how closely global climate progress is tied to what happens in forest-risk supply chains. Even though the summit did not deliver every breakthrough hoped for, it made clear that nature and land-use pressures are no longer side issues. 

They now sit at the centre of global climate expectations. It is in this broader context that the European Union introduced the Deforestation Regulation. The EU’s sustainability framework continues to expand through instruments like CSRD, CSDDD, the Taxonomy and SFDR, alongside ongoing efforts to simplify and streamline obligations through the 2025 Omnibus package. Most of these rules focus on reporting, governance and disclosure. EUDR is different. It requires companies to demonstrate, with verifiable geospatial information, where commodities come from and whether they meet strict deforestation-free and legality criteria.

Recent developments in Brussels also suggest that the regulation’s application date will be pushed back, with both the Parliament and Council supporting a one-year delay. Even with this postponement, the core expectations of the EUDR remain the same. Companies will still need reliable traceability, credible due diligence and strong supplier engagement to meet the regulation’s requirements once it takes effect.  

The following sections dive deeper into what this means in practice and how organisations can use this extended window to build the systems and capabilities needed for EUDR compliance.  

This article is written by Bart Ladru ([email protected]), and Kirill van der Velde ([email protected]) Bart and Kirill are part of RSM Netherlands Business Consulting Services, with a focus on Sustainability and Strategy.  

Timelines and the State of Negotiations  

The EUDR entered into force on 29 June 2023, with the first application date originally set for 30 December 2024. This was later postponed to 30 December 2025, reflecting early concerns about administrative burden and the readiness of national authorities to implement geolocation-based checks. Throughout 2025, these concerns resurfaced in the context of the broader Omnibus simplification wave, which aims to reduce reporting pressures and streamline sustainability rules across the EU. As a result, EUDR became part of a wider political discussion about regulatory workload and implementation capacity.  

Against this backdrop, the timeline has now shifted again. In November 2025, the European Parliament voted in favour of a further twelve-month postponement, moving the expected application date for medium and large operators to 30 December 2026, with micro and small operators following on 30 June 2027. The Council has aligned with this position, making a delay the most likely outcome as trilogue negotiations move toward a final agreement before the end of the year. As part of the same political package, the Commission will conduct a review in April 2026 to evaluate administrative burden and operational readiness. While this may lead to targeted adjustments or additional guidance, it is not expected to alter the fundamental structure of the regulation.  

It is important to emphasise that the negotiations affect timelines, not requirements. The commodity scope, the demand for plot-level geolocation data, the negligible-risk due-diligence standard and the use of the central EU Information System all remain unchanged. The delay simply provides a more feasible preparation window for companies, suppliers and competent authorities to build the systems and traceability processes that EUDR compliance will ultimately require.  

Who Is in Scope?  

The EUDR applies to operators: companies or natural persons who place relevant products on the EU market or export them from it, and to traders, who buy or sell these goods within the EU. Operators bear the primary legal responsibility for conducting due diligence and ensuring that all regulatory conditions are met. Traders have lighter obligations but must still store reference numbers of Due Diligence Statements and ensure that only compliant goods circulate downstream.

The regulation covers seven core commodities and a wide range of derived products identified by CN and HS codes. These include cattle (and leather, beef), cocoa (and chocolate), coffee, oil palm (and derivatives), rubber (including tires), soy (including oil and meal) and wood (covering timber, pulp, paper and furniture). Any product containing, processed from, or produced using these commodities may fall within scope, even if the in-scope material represents only a small share of the final product. For each shipment of these goods, operators must be able to demonstrate that they meet the EUDR’s deforestation-free and legality criteria and that the risk of non-compliance has been reduced to a negligible level.

Once companies establish that their products fall within scope, the next step is understanding what the regulation requires in practice.

What EUDR requires in practice  

EUDR compliance is built on the ability to show where production took place and whether that land meets the regulation’s deforestation-free and legality criteria. This moves companies beyond conventional supply chain mapping and into a system where each shipment must be linked to the specific plots of land that produced the relevant commodities. For many operators, this means understanding supply chains several tiers deeper than before, especially when sourcing through traders, cooperatives or intermediaries who do not directly manage farms or forest areas.  

This creates a more detailed operational landscape. Companies must collect accurate information on suppliers, production locations, product characteristics and the movement of materials through the chain. They must also ensure that compliant and non-compliant material are not mixed. The due diligence for each shipment must be backed by information that can be checked by authorities in the EU Information System.  

Central to this is plot-level geolocation. Production areas up to four hectares require a single coordinate. Larger areas require a full polygon that captures the boundary of the production plot. All data must be formatted in WGS84 so that the EU system can validate it through automated checks and comparison with satellite imagery. Incorrect coordinate systems, incomplete or distorted polygons and mismatched plot boundaries are common issues that must be resolved before a shipment can be cleared.  

For many upstream producers, especially smallholders, this type of data collection is new. Some rely on analogue land records, while others may not be familiar with GPS tools or basic mapping conventions. This means companies will need to invest in clear guidance, supplier communication and practical support. They will also need internal systems to verify, correct and store geolocation data, and to carry out the required risk assessment and mitigation steps.  

Building a reliable due diligence process  

The EUDR requires operators to maintain a due-diligence system capable of showing that products are deforestation-free, legally produced and linked to production plots where the risk of non-compliance is negligible. The process begins with collecting core information for every shipment, including product details, legality documentation, production dates and geolocation data. Using this information, operators must assess whether the product presents any risk related to deforestation or illegality. This includes evaluating local governance conditions, historical land-use patterns, supplier reliability and the structure of the supply chain. Once the Commission finalizes its risk benchmarking, country classifications will influence the level of due diligence required.

If uncertainty remains, operators must take proportionate steps to mitigate the risk. This may involve requesting more precise data, carrying out geospatial checks or engaging more directly with producers. The objective is to reach a point where the remaining risk can reasonably be considered negligible. Once this point is reached, a Due Diligence Statement is submitted through the EU Information System. All supporting evidence must be kept for at least five years. If negligible risk cannot be established, the regulation prohibits the goods from being placed on the EU market. Competent authorities may impose significant penalties, including turnover-based fines, confiscation of goods or temporary exclusion from public procurement if obligations are not met.

Why Geolocation Alone Is Not Enough  

Plot-level geolocation is central to EUDR, but on its own it does not provide a full picture of land-use history. Coordinates or polygons indicate where production took place, but they do not confirm what has happened on that land since the cut-off date of 31 December 2020. To build a credible due diligence process, many companies choose to compare plot data with independent sources that show whether recent deforestation or land conversion has occurred. This type of validation can draw on several tools, including satellite imagery, land cover classification datasets, tree-cover loss or forest-change layers and regional or national forest monitoring systems  

These sources help operators understand whether the supplied plot boundaries align with observable land use and whether any signs of recent deforestation require follow-up. While the EUDR does not prescribe specific datasets or methods, competent authorities will use similar techniques when verifying submissions. Performing these checks early can help companies identify potential issues before they become regulatory concerns.  

Some organisations also integrate automated geospatial validation into their internal workflows, particularly when sourcing from regions with many smallholders or where data quality varies. Such tools can highlight inconsistent polygons, incorrect coordinate systems or mismatches between plot boundaries and actual land cover. This offers a practical way to improve data quality and strengthen the overall due diligence process.  

Forward Thinking

As companies move toward implementation, many find that combining internal due-diligence workflows with geospatial tools offers clearer and more consistent results. Technology can support several essential steps such as validating coordinates and polygons, detecting signs of land-use change, resolving technical errors before submission, improving data consistency across suppliers and monitoring changes in land cover over time. These tools help transform raw geolocation inputs into information that can be meaningfully assessed, while also reducing manual workload and allowing teams to focus on interpreting risk rather than formatting data. For many organisations, this shift also brings a broader benefit. The process of assembling traceability information, supplier data and independent land-use verification creates a level of visibility that many supply chains have historically lacked. When these pieces of information are viewed together, companies gain a more complete understanding of upstream actors, potential bottlenecks and areas where oversight has been limited. In that sense, the EUDR does not only impose a compliance requirement; it also provides an opportunity to strengthen long-term supply-chain risk management.

COP30 underscored once again that the future of global climate policy hinges on how the world manages land use, forests and the supply chains linked to them. The EUDR is the EU’s regulatory expression of that shift. Even with a likely postponement of the application dates, the core expectations do not change as companies will need reliable data, strong supplier engagement and due diligence processes that can demonstrate negligible risk when reviewed by authorities.  

The extended timeline provides an opportunity rather than a pause. Organisations that use this period to strengthen supplier readiness, test geospatial workflows and build consistent internal processes will enter the next phase of EUDR with far greater certainty. By investing early in clear data pathways and practical compliance structures, companies can prepare not only for the regulation itself but also for a broader global shift toward more transparent and accountable supply chains.  

RSM is a thought leader in the field of Supply Chain Management consulting including sustainability matters. We offer frequent insights through training and sharing of thought leadership based on detailed knowledge of industry developments and practical applications in working with our customers. If you want to know more, please contact one of our consultants.  

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