EU Deforestation Regulation (EUDR, No. 2023/1115) It changes the way companies importing and marketing selected commodities (including timber, cocoa, coffee, palm oil, soy, rubber, beef, and related products) into the EU must manage their supply chains. The aim is to ensure that products on the European market do not contribute to deforestation or forest degradation.
For organizations, this means building a comprehensive due diligence system (DDS) and ensuring full supply chain transparency. Implementing EUDR is not a one-time project, but a process requiring a strategic, technological, and operational approach.
In this article, we present a practical step-by-step plan for implementing EUDR in an organization.
1. Understanding regulatory requirements
The first step is to thoroughly familiarize yourself with the EUDR regulations. Every company should clearly define:
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whether its products are included in Annex I of the Regulation,
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whether it plays the role of an operator (introducing products to the EU market for the first time) or a trader (distributor in the further chain),
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what responsibilities arise from her role.
It is also crucial to understand the terms:
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December 30, 2025 – effective date for large and medium-sized enterprises,
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June 30, 2026 – deadline for micro and small enterprises.
Already at this stage, it is worth seeking specialist advice or training to avoid misinterpretation.
2. Supply Chain Mapping
EUDR requires full traceability of the origin of raw materials and products. Therefore, an organization should:
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identify all suppliers and sub-suppliers,
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collect information about the countries of origin of raw materials,
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associate products with the appropriate CN/HS codes,
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determine which transactions are subject to regulation.
This is often the most time-consuming step, especially when the chain is complex and global. It's worth immediately implementing digital tools that allow for systematic data collection and verification.
3. Requirements for suppliers
To comply with the EUDR, providers must provide specific data and declarations, including:
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geolocation of agricultural/forest plots from which the raw material comes,
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information on compliance with the law of the country of production,
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documents confirming the legality of acquisition.
An organization should prepare communication forms and procedures for working with suppliers , taking into account cultural, linguistic, and legal differences. Educating suppliers is also crucial – many will be encountering such detailed requirements for the first time.
4. Building a Due Diligence System (DDS)
According to Articles 8–10 of the Regulation, the DDS system must include three pillars:
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Collecting information – data about the product, supplier, origin, geolocation.
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Risk assessment – analysis of the probability that a product comes from deforested areas or illegal sources.
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Mitigation measures – actions to reduce risk, e.g. supplier audits, additional certifications, satellite source verification.
Such a system should be documented, repeatable and capable of being presented to supervisory authorities.
5. Risk analysis and categorization
Every company must formally assess supply chain risks. Considerations include:
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country of origin (low, medium or high risk),
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level of supplier transparency,
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compliance history and previous violations,
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possibility of independent verification of data.
For high-risk situations, corrective action is necessary. Examples include implementing satellite geolocation analysis , using tools like EU Earth Observation or Reporting Assistant, or conducting audits of key suppliers.
6. Integration with IT systems and automation
Due to the scale of requirements and the volume of data, manual approaches quickly become inefficient. Therefore, organizations are increasingly using compliance platforms , such as Green Reporting's Reporting Assistant, which enable:
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central collection of data from suppliers,
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generating and submitting DDS declarations in the TRACES system,
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tracking the status and completeness of documentation,
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automation of reminders and communication with suppliers.
Technology becomes an essential element here – without it, maintaining compliance in the long term is almost impossible.
7. Internal procedures and training
EUDR implementation isn't limited to purchasing or compliance departments; it also involves logistics, trade, in-house counsel, and management. The following are essential:
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developing an EUDR policy within the organization,
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assigning responsibility within RACI (Responsible, Accountable, Consulted, Informed),
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regular training for operational and management teams,
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incorporating EUDR into purchasing and contracting procedures.
8. Monitoring, auditing and reporting
EUDR requires not only a one-time implementation but also ongoing monitoring. Organizations must be ready for:
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storing documentation for 5 years,
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inspections by supervisory authorities in the Member States,
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periodic risk updates and supplier verification,
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reporting in TRACES for each transaction subject to EUDR.
Regular internal and external audits help maintain a high level of compliance and prepare the organization for inspections.
9. Communication and transparency towards customers
EUDR also presents a business opportunity. Companies that effectively implement due diligence systems can leverage this as a competitive advantage:
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build customer trust through transparency,
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demonstrate environmental responsibility,
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win contracts with partners that require ESG compliance.
10. Implementation roadmap – where to start?
In summary, organizations should go through the following stages:
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Regulatory analysis – understanding requirements.
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Supply chain mapping – product and supplier identification.
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Communication with suppliers – obtaining data and declarations.
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DDS construction – procedures, tools, documentation.
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Risk assessment – categorization and corrective actions.
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IT implementation – process automation.
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Training and internal procedures.
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Monitoring and audits.
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Reporting in TRACES.
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Communication and ESG storytelling towards customers and investors.
Summary
Implementing the EUDR is a significant challenge, but also an opportunity to build a competitive advantage in global trade. Companies that begin preparations early will gain time to test processes, educate suppliers, and implement IT systems.
The key to success is the combination of regulatory knowledge, digital tools and effective change management within the organization.
Green Reporting supports companies in this process by providing technological and expert solutions that simplify EUDR Compliance and allow companies to focus on their business.
👉 Is your organization ready for EUDR? Contact us to learn how we can help you implement it effectively.