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This is a publication that is part of RSM's Voice of SCM. On a monthly basis, RSM issues the Voice of Supply Chain Management (SCM). Our consultants follow global developments and translate their impact into practical considerations for internationally active companies.
Compliance with the EU Deforestation Regulation (EUDR) applies to large and medium-sized operators from 30 December 2026, so companies should now turn their EUDR compliance plans into operational processes. That means testing whether suppliers can provide the required information, whether data quality is sufficient and whether internal processes work in practice.
The regulation marks the end of a lengthy transition period and introduces a new level of supply chain transparency in international trade for companies placing relevant products on the EU market. Although the additional implementation period provided organisations with more time to prepare, many businesses are still working to understand the practical implications of the regulation and the information required from suppliers. Recent updates to the regulation’s implementation guidance and clarifications regarding product scope make it worth reassessing readiness. Companies that performed initial gap assessments several years ago may find that assumptions made at the start of their compliance work no longer reflect current expectations.
This article was written by Kirill van der Velde (kvandervelde@rsmnl.nl) and Bart Ladru (bladru@rsmnl.nl). Kirill and Bart are consultants with RSM Netherlands with a focus on ESG and supply chain management.
Which products and supply chain responsibilities fall under the EUDR?
The first step towards compliance is determining whether products fall within the scope of the EUDR. The regulation covers commodities associated with deforestation and forest degradation risks, including cattle, cocoa, coffee, oil palm, rubber, soy and wood, as well as many derived and manufactured products. For many organisations, identifying affected goods is not always straightforward. Covered commodities may be embedded within larger products, components or packaging materials, requiring a detailed review of procurement data, product specifications and customs classifications.
A thorough scope assessment therefore goes beyond a simple product review and covers direct purchases, imported goods, private-label products and materials embedded within broader manufacturing processes. Businesses that operate across multiple jurisdictions or legal entities should also ensure that assessments are performed consistently across the entire organisation, reducing the risk of overlooking products that may trigger regulatory obligations.
Once product coverage has been established, companies should assess their role within the supply chain. Responsibilities under the EUDR differ depending on whether an organisation acts as an operator or trader and whether products are imported, placed on the market, made available within the EU or exported. These distinctions have a direct impact on due diligence obligations, recordkeeping requirements and the extent of information that must be collected and retained. This assessment can become particularly complex for organisations operating through multiple legal entities, distribution channels or sourcing arrangements. A company may act as an operator for some products while functioning as a trader for others. Understanding these distinctions early helps define ownership, allocate responsibilities and ensure that compliance processes are designed proportionately to the specific activities being performed.
How can companies build an effective supply chain due diligence process?
A key requirement of the EUDR is a supply chain due diligence process. Companies must be able to demonstrate that covered commodities are deforestation-free, produced in accordance with relevant legislation in the country of production and supported by comprehensive due diligence procedures. Compliance therefore relies heavily on the quality, completeness and reliability of information obtained from suppliers. For many organisations, supplier engagement represents the most resource-intensive aspect of implementation. Businesses need to gather information relating to sourcing origins, production areas, traceability systems and supporting documentation throughout the supply chain. This often requires engagement with suppliers several tiers upstream, including organisations that may have limited experience with EU regulatory requirements.
The challenge is compounded by the fact that supplier maturity levels vary considerably. Some suppliers have already established sophisticated traceability systems and dedicated compliance programmes, while others are still determining what information is required and how it can be obtained. As a result, companies should not assume that existing supplier relationships will automatically provide access to the information needed for EUDR compliance. To address these challenges, organisations should establish clear information requests, define internal review procedures and communicate expectations well in advance of the implementation date. Supplier onboarding processes, contractual requirements and procurement controls may also need to be revised to ensure that the necessary information can be collected consistently and efficiently.
In parallel, businesses should focus on embedding EUDR requirements into existing governance and compliance frameworks. This includes assigning clear responsibilities across procurement, sustainability, legal, compliance and supply chain management functions. Organisations should also document risk assessment methodologies, escalation procedures and decision-making criteria to ensure a consistent approach when evaluating supplier information. Technology will play a larger role in this work. Many companies are investing in systems capable of collecting traceability data, managing supplier documentation and supporting due diligence statement submissions. While technology can improve efficiency, it should be supported by clearly defined processes and governance arrangements to ensure that data is appropriately reviewed, validated and maintained.
How can companies close their EUDR compliance gaps before the deadline?
As the implementation date approaches, organisations should move beyond planning exercises and begin testing whether their compliance processes can function effectively in practice. The existence of a compliance framework alone does not guarantee readiness. Companies must assess whether supplier information can be obtained, whether data quality is sufficient and whether internal processes can support timely decision-making.
One of the most significant risks is supplier readiness. Even where a company has invested heavily in preparation, compliance may still be jeopardised if key suppliers cannot provide the required information or if traceability data cannot be verified. Incomplete information, inconsistent documentation or uncertainty regarding sourcing locations may create obstacles when demonstrating compliance and could affect the ability to place products on the EU market.
We therefore recommend targeted supplier readiness assessments to identify areas where additional support or engagement may be required. This may involve supplier training sessions, formal data collection exercises or pilot testing of traceability requirements. Early engagement provides suppliers with sufficient time to address deficiencies and reduces the likelihood of disruptions closer to the implementation deadline.
Companies should also consider performing end-to-end readiness reviews that replicate real-world compliance scenarios. These exercises can help identify weaknesses in governance arrangements, data collection processes, system capabilities or reporting procedures before regulatory obligations become effective. Attention should be given to suppliers operating in higher-risk regions, sourcing arrangements involving multiple intermediaries or product categories where traceability remains limited.
Beyond regulatory compliance, EUDR readiness is also a business continuity issue. Suppliers that are unable to provide sufficient information may present operational risks, while delays in due diligence processes could affect product availability, procurement timelines and customer commitments. Addressing these challenges now may help avoid costly disruptions once the regulation becomes applicable.
The remaining preparation period is therefore the time to close outstanding compliance gaps, strengthen supplier relationships and test due diligence processes under real operating conditions. Companies that use the coming months to move from planning to execution will be better positioned to meet EUDR requirements while minimising the risk of supply chain disruption, operational delays and last-minute remediation efforts. In our view, the companies best placed to meet the deadline treat EUDR compliance as part of how they manage their supply chain, rather than as a separate regulatory exercise.
RSM is a thought leader in the field of supply chain management including ESG. We provide frequent insights through training and thought leadership, based on detailed knowledge of industry developments and practical application gained from working with our clients. RSM helps companies connect individual geopolitical and regulatory developments to the broader changes affecting their supply chains. By doing so, we support businesses in distinguishing short-term disruption from structural change and translating that assessment into coordinated decisions on sourcing, origin, landed cost, logistics and supply chain design. If you would like to discuss what these connected developments mean for your business, please contact one of our consultants.
