As the compliance deadlines for the EU Deforestation Regulation (EUDR) approach, companies across various sectors are facing increasing pressure to familiarize themselves with the requirements and ensure they are prepared for the new due diligence processes. 

With large and medium-sized companies needing to meet the December 30, 2025 deadline, and other businesses by August 30, 2026, now is the time to understand the key provisions of the regulation. One of the central elements of compliance is the Information System, a digital platform that streamlines the submission of due diligence statements.

It is essential for companies involved in the import, export, and sale of commodities linked to deforestation to familiarize themselves with the system’s functionalities, such as submitting geolocation data, tracking supply chains, and ensuring traceability. As the launch of the Information System progresses, this article outlines the scope of the regulation, how businesses can comply, and the tools available to ensure a smooth transition to full compliance.

This article is written by Sefa Geçikli ([email protected]) and Iman Zalinyan ([email protected]). Sefa and Iman are part of RSM Netherlands Business Consulting Services, specifically focusing on Sustainability and Supply Chain Management. 

Who and What is Covered by the EUDR?

The regulation specifically targets companies that deal with commodities such as cattle, wood, cocoa, soy, palm oil, coffee, rubber, and products derived from these commodities (e.g., leather, chocolate, tires, or furniture). This means that any operator or trader placing these commodities on the EU market or exporting them from the EU will be required to comply with the regulation.

The EUDR also extends its requirements to entities involved in the import/export of in-scope commodities within the EU. To ensure compliance with the regulation, the EUDR classifies companies into different categories based on their size and operational scope. These categories determine the deadlines for compliance and the level of oversight each group will face. For large and medium companies, compliance must be achieved by December 30, 2025, while other companies will be required to comply by August 30, 2026.

The Information System for Due Diligence

A crucial aspect of the EUDR is the Information System, which is a digital database for submitting and managing due diligence statements. This system is designed to streamline the process of ensuring commodities are not linked to deforestation. Operators must submit due diligence statements electronically, which will then be checked in the registry and reviewed by the relevant Member States' authorities. 

The Information System is designed to significantly reduce administrative burdens and increase efficiency. It will include a feature called the Application Programming Interface (API), which allows operators and authorities to link their existing systems directly to the central registry, eliminating the need for manual uploads. Additionally, companies can reference previously submitted information, avoiding the need to resubmit identical data multiple times. The system was officially launched on December 4, 2024. Key milestones for the launch include:

  • January 2024: Testing conducted with 100 companies.
  • May 2024: The public was given access to the API, allowing for automated submissions.
  • August 2024: Companies were able to test geolocation files with the Commission IT service to ensure compatibility with the system.

Submitting Due Diligence Statements

The process for submitting due diligence statements within the Information System involves a few key steps:

  1. Indicating the Origin of Materials: Operators must specify the origin of their materials, which can be done by either drawing areas on a map or providing coordinates in bulk. For businesses dealing with commodities from multiple locations, there are options to upload or reuse location data, simplifying the process.
  2. Providing Details of the Products: To create a due diligence statement, operators must provide details about the products, including the HS code, product description, and quantity. Traders within the EU and operators further down the supply chain can reference previously created statements by using reference and verification numbers, either manually or via a CSV file.
  3. Managing Due Diligence Statements: Operators can track and manage their due diligence statements through a dashboard. The system updates the status of the statements as they are processed, ensuring transparency and monitoring throughout the process.

New Guidances on EUDR Compliance

The European Commission has recently issued several guidance documents to clarify the EUDR's requirements, addressing common misconceptions about the regulation.

For example, one myth that was debunked is the idea that every single grain of coffee must be tracked to its exact origin. In reality, companies do not always need to assign a specific product to a specific sourcing area. The regulation allows for aggregated traceability, meaning that companies can report on multiple sourcing areas collectively, even if they cannot trace a product back to a specific plot of land. Additionally, companies are allowed to “declare in excess” when only part of a batch is placed on the market, as long as they avoid mixing compliant and non-compliant products.

The European Commission, in partnership with the UNEP-WCMC, has also released a comprehensive guide to illustrate how the EUDR applies across various industries. This guide provides real-world examples, including:

  • Domestic Timber: Timber companies must ensure that all timber products, including logs, paper, and furniture, meet deforestation-free standards.
  • Imported Newspaper Paper: Paper importers and publishers must verify that the paper they handle is not linked to deforestation.
  • Beef Supply Chain: Farms, meat processors, and supermarkets must verify that beef is sourced from land not associated with deforestation.
  • Palm Oil Processing: Palm oil refiners and manufacturers, including those producing cosmetics, must confirm the deforestation-free origins of their raw materials.
  • Rubber & Tyre Manufacturing: Tyre manufacturers must demonstrate that the rubber they use does not contribute to deforestation.
  • Coffee & Cocoa: Companies involved in the coffee and chocolate industries must maintain traceability and geolocation data for their commodities.
  • Soy Supply Chain: Soybean crushing facilities must conduct due diligence, with the ability to refer to existing statements for processed products.

Also, in the Netherlands, Dutch Customs has recently shared the Questions and answers about EUDR page to guide companies in understanding the requirements. 

The Impact of the Omnibus Regulation on EUDR

The Omnibus Regulation is often cited in discussions around the EUDR, but it does not impact the existing requirements of the regulation. the Omnibus Regulation does not introduce any changes to the EUDR. Moreover, unlike CSRD and CSDDD, an EU Regulation is stronger than an EU Directive because it applies uniformly across all EU Member States without the need for national legislation. If a regulation conflicts with a directive, the regulation takes precedence. 

Looking Forward

As the compliance deadlines for the EU Deforestation Regulation (EUDR) draw near, businesses across multiple sectors must act swiftly to align their operations with the regulation's requirements. With large and medium-sized companies facing a deadline of December 30, 2025, and others needing to comply by August 30, 2026, the time to prepare is now. As companies begin to navigate the complex due diligence processes, understanding the Information System and how it streamlines the submission of due diligence statements will be crucial. After the deadline, non-compliant companies will not be able to continue their trading activities over the in-scope products.

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