The EUDR prohibits the sale or export of certain commodities into or out of the EU unless it can be demonstrated that they are deforestation-free and legally produced in the country of origin.

The regulation applies to companies that sell, import, or export the relevant products—either directly or as part of other goods—listed in Annex I of the EUDR. These include:

• Cattle
• Cocoa 
• Coffee
• Palm oil
• Rubber
• Soy
• Wood

Companies should consider conducting a broad due diligence process across their supply chain. This may include:

• Collecting the geolocation of the land plots used for production
• Confirming that the products are deforestation-free
• Assessing if they comply with local production laws
• Submitting a due diligence statement before placing products on the EU market or exporting them from it

Due diligence typically involves three core steps:

1. Information gathering: 

Collect and maintain data on the land plots where commodities were produced (geolocation) and supporting documents such as contracts, legal assessments, and certifications demonstrating compliance with local laws.

2. Risk assessment:

If the product comes from a “standard” or “high-risk” region, the collected information has to be evaluated to determine the risk of deforestation and legal noncompliance.

3. Risk mitigation:

If risks are identified, companies should consider implementing measures to reduce or eliminate those risks before marketing the product on the EU market or exporting it from the EU. This requirement applies to every product batch, regardless of whether the company already operates in the EU. A due diligence statement must be submitted through the EU’s Information System prior to placing the product on the market in accordance with Article 4 of the EUDR.

Without a valid due diligence statement—meaning one that is complete, accurate, submitted through the EU’s Information System, and includes required elements such as geolocation coordinates, confirmation of deforestation-free status, and compliance with relevant local laws—the product cannot be sold in, exported from, or imported to the EU. This requirement is outlined in Article 4(2) and Article 9 of the EUDR.

Yes. The EUDR distinguishes between operators and traders:

• Operators (placing a product on the EU market or exporting it for the first time) bear the main responsibility:

o Conduct due diligence on their suppliers;

o Maintain up-to-date records; and

o Submit a due diligence statement for each product batch.

• Large traders must also determine that due diligence was done properly by upstream operators. They are liable for breaches and verify the accuracy of information shared with them.

• EU-based companies that transform covered commodities (e.g., chocolate makers using imported cocoa butter) are considered operators and are responsible for determining if upstream due diligence has been completed.

If no due diligence statement is submitted, the product cannot be sold in, imported to, or exported from the EU market. Customs authorities may block the product at the EU border if it lacks a verified due diligence statement submitted through the EU’s Information System. This enforcement mechanism is outlined in Article 33 of the EUDR, which empowers Member States to designate authorities to inspect, investigate, and seize noncompliant products. 

Certification schemes can support compliance, but they do not replace the legal due diligence obligation under the EUDR. Companies may use certification data (e.g., farm-level audit results or sustainability verification reports) to help assess risk, but certificates alone do not constitute valid proof of compliance under the regulation, per Recital 52 of the EUDR. 

Yes. While upstream producers who do not directly place products on the EU market are not legally bound by EUDR, they are still indirectly affected. These producers will often need to provide important data—such as geolocation of production plots and proof of compliance with local laws—to help EU operators fulfill their due diligence obligations, per Article 4(1) and Article 9 of EUDR.

If producers cannot supply this information, EU operators may be forced to find alternative sources that can meet EUDR requirements. While operators are the legally accountable reporters, they depend on their suppliers to provide traceable and verifiable information. This dynamic creates business pressure across the supply chain. Suppliers who cannot meet documentation expectations may risk losing access to EU markets or preferred buyer relationships. 

Technology is important for EUDR compliance. It can enable companies to collect, integrate, and validate data across the supply chain. Tools like blockchain, geospatial mapping, and traceability platforms can help track commodities back to their source and verify deforestation-free status.

Technology supports:

• Capturing geolocation coordinates of production plots (a core EUDR requirements).
• Centralizing and sharing due diligence documentation.
• Automating risk assessments and assurance readiness.