EUDR Due Diligence: What Is Actually Required

The EU Deforestation Regulation is unusual among product rules in that it asks for coordinates. Not a policy, not an assurance, not a supplier code of conduct — the latitude and longitude of the land the commodity grew on.

That specificity is why programmes fail on geometry rather than on documentation. Companies with mature responsible sourcing policies routinely discover they cannot produce a plot boundary for material they have been buying for a decade.

What is actually in scope

Regulation (EU) 2023/1115 covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, and crucially the products derived from them. That derived-products clause is what pulls in categories nobody expects.

The practical consequence is that a footwear brand, a cosmetics manufacturer and a furniture retailer are all in scope, frequently without having considered themselves affected by a deforestation regulation.

The three obligations

Compliance is built on three requirements that must all hold before the goods are placed on the market.

1. Deforestation-free. The commodity was produced on land not deforested after 31 December 2020. The cut-off is fixed and does not move with local law.
2. Legally produced. Production complied with the relevant legislation of the country of production, covering land use rights, environmental and labour law, and taxes.
3. Covered by a due diligence statement. Lodged in the EU information system before placing on the market, and referenced downstream.

Why geometry is where it breaks

Article 9 requires geolocation of all plots of production. For plots above four hectares that means a polygon — the boundary of the land — rather than a single coordinate.

The reasoning is straightforward once stated. A point on a sixty-hectare estate tells you nothing about whether the specific area the crop came from was forest in 2021. Only a boundary allows satellite imagery to be checked against the cut-off.

Collecting polygons from smallholders is the practical difficulty. A cooperative aggregating output from hundreds of farms has historically recorded membership rather than land boundaries, and gathering them requires field work rather than a data request.

How the statement moves downstream

A due diligence statement carries a reference number, and that reference is what downstream operators rely on when making their own statement. This creates a chain that is easy to break.

The failure mode is a missing reference at any point, which forces the operator below to reconstruct the underlying evidence themselves. In practice that usually means they cannot, and the material becomes unusable for the EU market.

Risk assessment and mitigation

Geolocation alone does not discharge the obligation. An operator must assess the risk that the goods are non-compliant, taking account of the country benchmarking, the complexity of the supply chain, and the reliability of the information collected.

Where risk is not negligible, mitigation is required before the statement can be made — additional information, independent surveys, or audits. The practical difficulty is that mitigation takes time the shipping schedule rarely allows, which is why risk assessment belongs at supplier qualification rather than at the point of import.

Where this meets the product passport

EUDR data and passport data are the same collection exercise approached from different regulations. Both need to know what a product contains, where the material came from, and who asserted it.

A company running them separately builds two supplier engagement programmes against overlapping supplier lists, produces two sets of provenance records, and discovers they disagree. Running them together means the geolocation collected for EUDR becomes the origin attribute the passport needs.

The sequencing advantage is real too. EUDR is in force ahead of most ESPR delegated acts, so a company that builds deep-tier traceability for deforestation compliance has already built the hardest part of its passport programme before the passport deadline arrives.