EUDR: the complete guide to bringing your supply chain into compliance.

The EUDR in brief

EUDR / RDUE: definition, scope and relevant products

Whether you are looking for the meaning of RDUE, come across the words “EUDR regulation” in an international contract or type “EURD” or “EUDR réglementation”, you end up at the same text: Regulation (EU) 2023/1115.

What the regulation requires, in three conditions

To be placed on the EU market or exported, a relevant product must meet three cumulative conditions:

1. Deforestation-free: the commodity does not come from land deforested after 31 December 2020. For wood, an additional criterion covers forest degradation.
2. Compliance with the legislation of the country of production: land rights, environmental law, labour law, tax and customs obligations, rights of local communities.
3. Due diligence exercised, evidenced by a due diligence statement.

The cut-off date of 31 December 2020 is a legally enforceable criterion. It changes the level of historical information required from the supplier.

Which commodities, which products?

Who is affected? Three roles not to be confused

The regulation has been simplified: due diligence and the statement are concentrated on the operator that places the product on the Union market for the first time. Downstream players nevertheless retain obligations for upstream and downstream traceability and for keeping information.

In France, who carries out checks?

The competent authorities are the ministries in charge of Ecological Transition and Agriculture. Customs (DGDDI) act at import; the DGCCRF retains its powers over the internal market without being the EUDR competent authority.

“Relevant commodities and relevant products shall not be placed or made available on the market or exported, unless all the following conditions are fulfilled: (a) they are deforestation-free; (b) they have been produced in accordance with the relevant legislation of the country of production; and (c) they are covered by a due diligence statement or a simplified declaration, as required by the relevant provisions of this Regulation.”Regulation (EU) 2023/1115, Article 3 · consolidated text, EUR-Lex

EUDR timeline: applicable dates in 2026-2027 and what has changed

What the 2025 amendment changed

• Due diligence concentrated on the first operator on the EU market.
• End of the “cascading” statement: downstream operators retrieve and keep the statement reference of the first player.
• Traceability maintained: identification of direct suppliers and business customers, keeping of information (generally five years).
• Registration: non-SME downstream operators and traders may have to register in the information system.

What the July 2026 revision added

On 13 July 2026, the Commission adopted two texts. Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, amends Annex I:

• removed from scope: bovine hides and skins, retreaded tyres (tread), soya for sowing, belts and articles of vulcanised rubber, aircraft and motor vehicle seats;
• added, applicable from 30 December 2027: soluble coffee, frozen bovine tongues, palm oil derivatives (fatty alcohols, glycerol, acids, amines, soaps);
• exclusions clarified: samples, waste and second-hand goods, single-use packaging, paper marketing materials, certain oleochemicals intended for medicinal products.

Implementing Regulation (EU) 2026/1565 sets out the rules for the information system: a single simplified declaration for micro and small primary operators, grouping of statements and a procedure in the event of an outage. The simplification review of May 2026 confirmed that no further postponement is planned.

The regulation’s practical requirements: Articles 4, 9, 10, 11 and 25

Article 9: the information to collect

• product description, trade name, type, commodities used and quantity;
• country of production and geolocation of all plots of land (for cattle, of the establishments where they were kept);
• date or time range of production;
• identification of suppliers and business recipients;
• evidence of deforestation-free status and legal compliance.

Article 10: risk assessment

The operator analyses this information and concludes that there is no or only negligible risk. The criteria include the country’s risk level, the presence of forests, illegal production, the reliability of documents, the complexity of the supply chain, the risk of mixing and land tenure rights.

Article 11: risk mitigation

If a risk that is more than negligible remains, the operator puts mitigation measures in place. It cannot place the product on the market until the risk has been reduced to no or negligible risk.

Article 4: the due diligence statement (DDS)

The statement (Due Diligence Statement) is submitted in the EUDR information system, hosted in TRACES. The system assigns a reference number to be linked to the products. The statement and supporting documents are kept for at least five years. Content, submission and retention: see our DDS guide.

Article 25: penalties

Member States set their own penalties. The legal ceiling for fines must be at least 4% of total annual turnover in the EU. On top of this come confiscation of products and revenues, temporary exclusion from public procurement and, in some cases, a temporary ban on trading. It is therefore not an automatic 4% fine, but a floor for the ceiling.

From EUDR obligations to internal processes

Plot geolocation: polygons, GPS points and the 4-hectare threshold

This is the most technical point of the regulation, and the one that most often causes supplier files to fail. Collection methods, formats and quality control: see our plot geolocation guide.

1. The threshold refers to “more than 4 hectares”: a plot of exactly 4 hectares can be declared by a point.
2. The area that counts is that of the production plot, not the total area of the farm.
3. A polygon follows the actual boundaries of the plot, with enough points to describe it.

Technical format: GeoJSON

The expected format is GeoJSON (RFC 7946), in WGS 84 / EPSG:4326:

• coordinates in decimal degrees, at least six decimal places;
• longitude, latitude order (not the other way round);
• closed polygon ring (first point repeated at the end of the list), at least four positions;
• self-intersecting polygons and holes not supported;
• transmission via API in a base64-encoded geometry field.

• Checklist before any submission
• The CN code of the relevant product is confirmed.
• Each upstream plot is identified with its supplier and its batch.
• Plots of more than 4 ha have a polygon.
• Coordinates have at least six decimal places, in longitude-latitude order.
• Geometries are closed and free of self-intersections.
• The unit of measure and the date of production are filled in.
• The GeoJSON file is validated before submission.

Supplier data collection: what to ask for, how, and in what format

EUDR compliance is won or lost upstream, with direct and indirect suppliers. The goal: complete, consistent and traceable data, without overloading purchasing teams.

How to structure collection

1. Segment suppliers by criticality (commodity × country × chain complexity).
2. Standardise the questionnaire and expected formats, including the geo format.
3. Open a dedicated channel: a supplier portal cuts down email back-and-forth and shows who filled in what.
4. Check on receipt: completeness, geographical consistency, file validity, batch matching.
5. Version each dataset: a geolocation that changes must be kept in the history.

The three collection pitfalls

• The “black box” supplier that does not know its own upstream suppliers: plan for support and a schedule.
• Isolated data: a geolocation not linked to a batch proves nothing.
• Collection by email: without a structured channel, you end up rebuilding the data by hand when the check comes.

Where each piece of EUDR data lives: ERP, PLM and PIM

The key question is rarely “what does the regulation say?” but “where do we plug in the EUDR data?”. The ERP manages flows (purchasing, stock, batches), the PLM holds product composition, the PIM publishes product information. The detailed data model is in our supplier data and ERP guide.

IT integration: the five requirements to define

1. A common identifier between ERP item, PLM/PIM product and Annex I commodity.
2. A batch → geographical origin link: without it, no statement can be justified.
3. Geographical master data able to store points and polygons and export valid GeoJSON.
4. Versioned document management, with expiry dates and owners.
5. An exposure point to the EUDR information system (manual submission or API).

The goal is not to add a tool, but to know which system is the source of truth for each field, and how identifiers flow.

Supplier risk assessment: criteria and method

The assessment combines country risk, product risk and supplier risk.

Step 1: retrieve the country benchmarking

Country benchmarking was set by Implementing Regulation (EU) 2025/1093 of 22 May 2025. The high-risk countries listed are Belarus, North Korea, Myanmar and Russia; low-risk countries are listed in the annex (including the Member States); all others are standard risk. Check the version in force on the date of sourcing.

Step 2: cross-check the Article 10 criteria

• risk level of the country or region;
• presence of forests and extent of observed deforestation;
• prevalence of illegal production;
• reliability and verifiability of the documents provided;
• complexity of the supply chain and risk of mixing;
• land tenure rights and rights of indigenous peoples;
• relevant certifications and third-party information.

Step 3: decide

This process ties in with supplier assessment: reuse the same governance, the same campaigns and the same criticality scale.

EUDR audit readiness: proving compliance in the event of a check

A check needs preparing: the point is to be able to produce, at short notice, the complete chain of evidence for a given product. The full list, topic by topic, is in our EUDR audit checklist.

The standard file for a product

• Qualification: CN code, Annex I wording, justification for inclusion or exclusion.
• Role: operator, downstream operator or trader, with the reasoning.
• Origin: country, region, plots of land, geolocation in the expected format.
• Valid proof of legality.
• Due diligence: information collected, assessment, conclusion.
• Statement: DDS reference and link to batches.
• Retention for at least five years, and responsibilities: who approved what, and when.

The criteria of a robust file

Questions to ask before a check

1. If a check came tomorrow, which product is the most vulnerable?
2. How long does it take to rebuild a complete file?
3. Who in the company knows where each piece of evidence is?
4. Is the file the same whether rebuilt from the ERP or from the PIM?

Sector cases: cocoa, coffee, palm oil, soya, wood and packaging

Common mistakes that block compliance

1. Confusing commodity with actual scope: only the CN code checked against Annex I decides.
2. Pinning the project on an outdated date: remember 30 December 2026, 30 June 2027 and 30 December 2027 for the added products.
3. Accepting a GPS point for a plot of more than 4 hectares.
4. Sending coordinates in latitude-longitude order: the GeoJSON order is longitude, latitude.
5. Collecting geometries without linking them to a batch.
6. Believing that a certification equals compliance: FSC, RSPO, GFSI or CSRD do not exempt you from due diligence.
7. Ignoring support packaging or, conversely, wrongly excluding packaging sold as a product.
8. Not keeping a history of the versions of a corrected geolocation.

90-day EUDR roadmap

Goal: by day 90, a clear scope, supplier data being collected and a tested evidence file.

1. Days 1 to 30Define the scope and roles
   • Check CN codes against Annex I
   • Determine role and size per product
   • Appoint the governance: Quality, Purchasing, Regulatory, IT, CSR
   • Draw up the obligations / processes / systems matrix
   End of phase: scope qualified
2. Days 31 to 60Collect and structure the data
   • Segment suppliers and launch collection
   • Set the geo format (GeoJSON, WGS 84)
   • Lock down item / supplier / batch identifiers
   • Set up document management for evidence
   End of phase: supplier campaign under way
3. Days 61 to 90Assess, test, prepare for the check
   • Apply the risk grid and mitigation measures
   • Prepare submission and DDS references
   • Test audit readiness on the most exposed product
   • Prioritise gaps until the applicable date
   End of phase: evidence file tested

• Steering checklist
• Product scope qualified (CN code / Annex I).
• Entity role documented per product.
• Suppliers segmented and collection campaign launched.
• Geo format defined and checked.
• Allocation of data between ERP, PLM, PIM and supplier record decided.
• Risk grid applied.
• Evidence file tested.