Deforestation is one of the most pressing challenges of our time. It drives climate change, destroys biodiversity, undermines indigenous rights, and disrupts water cycles and food systems. Between 1990 and 2020, the world lost an area of forest larger than the European Union, more than 420 million hectares. This is no longer just an environmental issue; it’s a business risk with far-reaching implications across global supply chains.
Despite years of voluntary pledges, certification schemes, and sustainability commitments, the pace of forest loss has not slowed enough. Deforestation linked to agricultural commodities is still the primary cause of forest degradation. According to WWF, in 2017 alone, European consumption was responsible for 16% of tropical deforestation tied to international trade. Products like beef, soy, cocoa, and palm oil may seem far removed from policy debates, but they are at the heart of this crisis and deeply embedded in the EU economy.
That’s why the European Union introduced the EU Deforestation Regulation (EUDR) in June 2023. Building on the earlier EU Timber Regulation (EUTR), this new law goes several steps further. It makes it illegal to place certain commodities and their derived products on the EU market, or export them, unless they are
- Deforestation-free (i.e., not linked to land cleared or degraded after 31 December 2020),
- Legally produced in their country of origin, and
- Backed by a due diligence statement confirming low or no risk of non-compliance.
The regulation is part of the EU Green Deal and reflects a broader shift happening worldwide: from voluntary ESG measures to mandatory, enforceable sustainability laws. Alongside the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD), the EUDR signals a new era of accountability where companies are expected to trace, assess, and justify the origins of their products with a level of precision that wasn’t previously required.
For businesses, this is a wake-up call and an opportunity. The EUDR introduces new compliance costs and operational challenges, especially for companies with deep or complex supply chains. But it also offers a chance to build greater transparency, resilience, and trust. Investors, customers, and regulators are all pushing in the same direction: toward cleaner, more ethical, and more future-fit supply chains. Those who act now will be better positioned to adapt not just to EUDR but to the wider wave of sustainability regulation reshaping global trade.
In the article ahead, we’ll walk through everything you need to know about the EUDR: what’s covered, who’s affected, what the due diligence process looks like, and how to get your systems and suppliers ready. Because this isn’t just about forests, it’s about the future of your business in a world that’s rapidly rebalancing around nature, people, and long-term value.
What is the EUDR?
The EU Deforestation Regulation (EUDR) is a landmark law adopted in 2023 to combat global deforestation driven by the European Union’s consumption of high-risk commodities. In simple terms, EUDR says, if you want to sell certain products in the EU, they must be deforestation-free, legally produced, and traceable back to the source. No deforestation, no deal.
The regulation was created with three key goals:
- To minimize the EU’s contribution to global deforestation and forest degradation.
- To reduce greenhouse gas emissions linked to land-use change.
- To promote sustainable, transparent supply chains.
At its core, EUDR is both an environmental and economic instrument. It applies to seven key commodities: cattle, cocoa, coffee, palm oil, soy, wood, and rubber, and a wide range of derived products made from or containing these raw materials. Whether it’s a leather bag, a chocolate bar, or plywood flooring, if it contains one of these commodities, it falls under the EUDR scope.
The regulation introduces three non-negotiable criteria that must be met for these goods to be placed on or exported from the EU market:
- Deforestation-Free: The product must not have contributed to deforestation or forest degradation after 31 December 2020.
- Legally Produced: It must comply with all applicable laws in the country of production, including those related to land use, labor rights, and environmental protection.
- Traceable and Declared: Companies must conduct due diligence and submit a formal statement confirming low or no risk of non-compliance.
What sets the EUDR apart is that it’s mandatory, backed by regulatory enforcement, and tied directly to market access. Companies can no longer rely solely on voluntary certifications or sustainability marketing. They must prove compliance by submitting detailed digital due diligence statements through a new EU system, including evidence like satellite imagery, plot-level geo-coordinates, and supplier risk assessments.
This law applies not only to EU-based companies but also to any business, anywhere in the world, that exports covered goods to the EU. That makes EUDR one of the most far-reaching sustainability regulations ever introduced. The EUDR isn’t just about stopping illegal logging or saving a few forests. It’s about reshaping how global supply chains work, making transparency the norm, not the exception. We are happy to see that this is a clear signal that sustainability is no longer a side project; it’s now a legal and strategic requirement for doing business in the EU.
Who Does the EUDR Apply To?
The EUDR applies to a wide range of businesses involved in producing, importing, exporting, or selling any of the covered commodities or their derived products within the European Union. But not everyone is affected in the same way. The regulation introduces specific roles operators and traders, and defines responsibilities based on company size, location in the value chain, and whether the business is EU- or non-EU-based.
Operators are the companies that first place a regulated commodity or product on the EU market or export it from the EU. This includes importers, manufacturers, and brand owners. If your business brings a covered product into the EU or sends it out, you’re an operator under EUDR. You carry the full weight of the regulation: collecting data, assessing and mitigating risk, and submitting due diligence statements to the EU information system.
Traders, on the other hand, are companies that make these products available within the EU market but do not import or manufacture them themselves. These are often wholesalers, retailers, or distributors. Traders have fewer obligations than operators, especially if they qualify as small or micro-enterprises. But they’re still required to ensure traceability, maintain records, and refer to the due diligence statements submitted upstream.
Whether your company is inside or outside the EU, the regulation still applies if you’re trading with the EU. Non-EU companies that export goods covered by the EUDR to the EU must work with their supply chain partners to provide all necessary data, from farm-level geolocation to legal compliance evidence. This effectively pulls global suppliers, cooperatives, and producers into the compliance process, even if they’re not directly regulated.
Company size also affects compliance obligations. Small and medium-sized enterprises (SMEs) benefit from extended deadlines and, in some cases, simplified requirements. For example, SMEs that are traders only need to keep records of due diligence statements for five years, while operators, regardless of size, must conduct full due diligence and maintain an internal system for monitoring and documenting risks. According to EU criteria, an SME is defined as having fewer than 250 employees and either a turnover below €50 million or a balance sheet under €43 million.
Here’s how obligations break down:
- Non-SME operators (e.g., a large cocoa importer): Full due diligence required.
- SME operators (e.g., a small chocolate maker sourcing raw beans): Full due diligence, but extended compliance timeline.
- Non-SME traders (e.g., large retailers): Must verify due diligence and retain records.
- SME traders (e.g., small wholesalers): Limited to recordkeeping and referencing existing due diligence.
In short, if your company has a role in placing or moving these products through the EU market, whether directly or indirectly, you’ll need to pay attention to how you’re classified under the EUDR. And even if you’re not submitting statements yourself, your partners upstream or downstream might need your support to stay compliant.
What Commodities and Products Are Covered?
The EUDR focuses on seven commodities most strongly linked to deforestation and forest degradation. These are cattle, cocoa, coffee, oil palm, rubber, soya, and wood. But the regulation doesn’t stop at raw materials; it also covers a long list of derived and composite products made from or containing these commodities, from leather shoes and chocolate to plywood and printed paper.
To avoid ambiguity, the regulation uses a specific trade classification system: the Harmonised System (HS) codes. Every product traded internationally is assigned a code under this system. Annex I of the EUDR lists the exact HS codes for all covered products. This level of precision helps customs authorities, companies, and auditors identify which goods fall under the regulation. If your product’s HS code is on the list, it’s in scope. If it’s not, it isn’t.
An overview of Covered Commodities:
- Cattle – including meat, leather, and other hides or offal.
- Cocoa – raw beans, cocoa paste, butter, powder, and chocolate products.
- Coffee – roasted or unroasted, decaffeinated, and coffee substitutes.
- Oil Palm – palm oil and its fractions, palm kernel oil, and industrial by-products like stearic and oleic acid.
- Rubber – natural rubber and a variety of processed rubber products, including tyres, gloves, hoses, and rubber belts.
- Soya – soybeans, oil, flour, and soy-based animal feed.
- Wood – logs, sawn timber, wood panels, furniture, pulp, paper, and wooden packaging materials.
Derived and Composite Products
What makes EUDR especially impactful is that it doesn’t only regulate raw materials. Products that are processed, mixed, or manufactured from the above commodities are also covered.
For example:
- A chocolate bar (cocoa and potentially palm oil)
- A leather handbag (cattle)
- Wooden furniture or floorboards (wood)
- Tyres or footwear (rubber)
If a product contains multiple commodities, only the most relevant commodity is assessed for compliance. For instance, if a chocolate bar contains both cocoa and palm oil, cocoa is the primary focus unless palm oil is the dominant input.
The “ex” Factor in HS Codes
Some entries in Annex I are marked with “ex”—this means only a subset of the HS code is affected. For example, the broader category might include several wood-based products, but only those made from natural forest timber would fall under the EUDR. Businesses need to check the specifics carefully to avoid false assumptions about what’s included.
Why Scope Matters
Getting the scope wrong can result in either non-compliance or unnecessary work. Some products, like soap containing palm oil, may not be covered because the HS code falls outside Annex I. On the other hand, packaging and secondary ingredients might fall within the scope, depending on how the product is classified. This is why companies need to go beyond commodity names and review their product codes and sourcing declarations in detail. Ultimately, the EUDR’s scope is broad by design. It captures both the direct and indirect impact of EU consumption on global forests and aims to push transparency deep into supply chains, regardless of how many steps separate the final product from the original farm or forest.
Timeline: When Does the EUDR Apply?
The EUDR entered into force on 29 June 2023, but its requirements aren’t applied all at once. To give companies time to adapt, the EU has introduced a phased implementation timeline based on company size. Understanding when obligations are necessary is critical for planning, especially for companies still mapping their supply chains or rolling out digital traceability systems.
Key Milestones:
- 29 June 2023 – Regulation entered into force
- 30 December 2024 – Original application date for main obligations (later adjusted)
- 30 December 2025 – New application deadline for large and medium-sized companies
- 30 June 2026 – Extended deadline for small and micro-enterprises (SMEs)
This timeline gives larger companies roughly 18 months from the official entry into force to become fully compliant. SMEs benefit from an additional six-month grace period, reflecting their generally lower resources and capacity.
What Needs to Be Ready by the Deadline?
By the time the regulation applies to your company, you must be able to
- Identify and trace all relevant products and commodities in your portfolio.
- Collect geolocation data for plots of land where the commodities were produced.
- Conduct risk assessments based on country of origin and supply chain factors.
- Implement risk mitigation measures where necessary.
- Submit a due diligence statement digitally before placing goods on the EU market or exporting them.
No Retroactive Checks, but No Loopholes Either
The EUDR does not apply retroactively to products already on the market before the relevant deadline. However, any product placed on the EU market on or after the application date must meet all requirements. This means companies cannot bypass compliance by pre-shipping non-compliant stock or relying on buffer inventories.
It’s also worth noting that for some product categories, goods move through the supply chain slowly. For example, tropical hardwood furniture or long-shelf-life food items may take months to reach consumers. Companies must ensure that traceability and documentation are maintained even if the product doesn’t sell immediately.
Start Early
While December 2025 or 2026 may sound far off, we foresee companies that wait until the last minute will likely struggle. Tasks like mapping supply chains, collecting farm-level data, training teams, and engaging suppliers all take time. And tools like traceability software or satellite verification platforms can take months to implement properly. That’s why both the European Commission and industry advisors strongly recommend starting now, especially for companies with complex, multi-tiered sourcing networks.
What Companies Need to Do (Core Requirements)
To comply with the EUDR, companies need to follow a structured due diligence process before placing regulated products on the EU market or exporting them from the EU. This isn’t a one-time activity, it’s a repeatable process that must be embedded into day-to-day operations.
The regulation lays out three main obligations:
- A due diligence process with three clear steps.
- Compliance with deforestation-free and legal production criteria.
- Submission of a formal due diligence statement via the EU’s information system.
Let’s go through what each of these means in practice.
1.1 Due Diligence Process
At the core of the EUDR is a three-step due diligence framework that must be completed before any relevant product enters or leaves the EU market.
These steps are:
Step 1: Information Gathering
You must collect and document the following:
- Commodity type, quantity, and country of production
- Geolocation data (latitude and longitude) for the plot(s) of land where the commodity was produced
- For cattle, this includes all relevant locations where animals were kept
- Production date or time range
- Supplier name(s) and chain-of-custody documentation
- Proof of legal compliance in the country of origin
This is one of the most resource-intensive parts of EUDR compliance. In fragmented supply chains (e.g., cocoa or coffee), collaboration with cooperatives, first-mile traceability platforms, or on-the-ground partners may be required. Many companies are turning to satellite services and blockchain or QR-based tools to map sourcing areas and verify farm locations.
Step 2: Risk Assessment
Once information is collected, companies must assess the risk that a product is
- Linked to deforestation or forest degradation
- Not legally produced
The EUDR allows businesses to factor in:
- The country of origin’s risk classification (low, standard, or high risk—see next paragraph)
- The presence of indigenous communities
- Land tenure disputes, corruption, conflict, or weak environmental enforcement
- Supplier history and certifications
This assessment must be documented and justifiable. Even for low-risk countries, companies are still required to show that they’ve performed this step.
Step 3: Risk Mitigation
If there is any non-negligible risk, companies must take action before placing the product on the market.
Risk mitigation might include:
- Requesting additional documentation from suppliers
- Conducting or commissioning audits
- Changing suppliers
- Providing training or capacity-building programs for smallholders
Operators are not allowed to simply accept risk; they must reduce it to negligible or withhold the product from the market.
2.1 Deforestation-Free and Legally Produced
In addition to due diligence, products must meet two essential criteria:
- Deforestation-free: The commodity must not be linked to any deforestation or forest degradation that occurred after 31 December 2020. This includes legal deforestation; if land was cleared in line with national laws after that date, the product still doesn’t comply.
- Legally produced: All local laws in the country of origin must be respected, including those relating to land use, labor rights, environmental protection, and indigenous land tenure.
This dual requirement is one of the EUDR’s strongest features; it closes the loophole often used by businesses that argue compliance with national law alone is enough.
3.1 Submitting a Due Diligence Statement
The final step is to submit a due diligence statement via the EU’s central information system, declaring that:
- All due diligence steps were completed
- The product meets deforestation-free and legal origin criteria
- The risk of non-compliance is negligible
Each statement is linked to specific product batches or shipments and remains valid for up to one year or until the declared volume is exhausted. For companies placing the same products on the market repeatedly, statements can be reused where appropriate.
Statements must include:
- Operator name and EORI number (where applicable)
- HS code and product description
- Geolocation data
- Reference numbers to previous statements (for downstream actors)
- A declaration of negligible risk and compliance
Even where smaller traders only refer to existing statements, they must retain records for five years and verify that the upstream operator has done their job correctly.
Practical Example: Tony’s Chocolonely and Cocoa Compliance
Let’s say you’re a chocolate company like Tony’s Chocolonely, sourcing cocoa beans from Ghana and Côte d’Ivoire, two regions with a high historical risk of deforestation. Here’s what EUDR compliance looks like in real life:
Step 1: Information Gathering
Tony’s needs to trace every cocoa bean back to the exact farm where it was grown. That means collecting the following:
- Geolocation coordinates for each farm plot supplying their beans
- Information about the production season and volume harvested
- Legal documentation proving land rights and farm ownership
- Details about the cooperatives or suppliers they buy from
Tony’s uses its own traceability platform, Beantracker, to monitor supply chain data and ensure traceability from bean to bar.
Step 2: Risk Assessment
Even with this data, risk remains high due to regional issues like illegal land clearing, unclear land tenure, and weak enforcement of environmental laws. Tony’s uses a mix of:
- Satellite imagery to detect forest loss
- Country profiles to assess governance and law enforcement risks
- Supplier history to review past sourcing issues
If a farm is too close to recently deforested land, it flags a higher risk, even if the beans themselves came from a legal source.
Step 3: Risk Mitigation
For farms with elevated risk, Tony’s takes extra steps:
- Conducting field audits
- Training farmers on no-deforestation practices
- Verifying supplier compliance through third-party checks
- Supporting farmers to gain land title documentation
If any farm doesn’t meet the criteria, it’s excluded from the sourcing list.
Due Diligence Statement
Before placing chocolate products on the EU market, Tony’s submits a digital statement through the EU system. It confirms that:
- Due diligence has been performed
- Risks are negligible
- All cocoa in the batch is deforestation-free and legally produced
The statement is linked to geolocation and supplier data already uploaded through their traceability system.
This example shows how even mission-driven companies need to go beyond certifications and invest in data systems, supplier relationships, and risk analysis to meet EUDR standards. It also highlights the importance of long-term partnerships and tech-enabled traceability in building a compliant, ethical supply chain.
Country Benchmarking System: How Risk Levels Are Assessed
To make due diligence more proportionate, the European Commission has developing a country benchmarking system that classifies the deforestation risk level of countries or regions. This system will influence the depth of risk assessment that companies must carry out when sourcing products.
Countries will be placed into one of three categories:
- Low Risk – where deforestation and forest degradation are rare and governance is strong
- Standard Risk – the default category until further data is available
- High Risk – where deforestation is common and enforcement is weak
This classification won’t just be symbolic. It has direct compliance implications:
- Companies sourcing only from low-risk areas can apply simplified due diligence procedures (still requiring documentation, but fewer verification steps).
- Products from high-risk areas will trigger more extensive risk assessments and possibly stricter mitigation measures.
Why This Matters
For companies sourcing from multiple countries, benchmarking simplifies prioritization. Instead of treating all suppliers equally, businesses can allocate resources where the risks, and the stakes are highest. Even in low-risk countries, traceability and legality requirements still apply, and due diligence statements are still mandatory.
In practice, this means companies will need systems that can track not just suppliers but also locations and flag risk exposure as country profiles evolve. Investing in flexible tools and adaptive sourcing strategies will be key to staying compliant and ahead of the curve.
How the EUDR Relates to Other EU ESG Laws
The EUDR is part of a broader movement in the EU aimed at transforming corporate accountability through sustainability regulation. Together with laws like the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD, also known as CS3D), the EUDR helps shape a new compliance ecosystem, one where human rights, environmental responsibility, and traceability are legally enforced rather than optional.
Connecting the Dots: EUDR, CSRD, and CSDDD
Let’s look at what they envision:
- EUDR focuses specifically on deforestation-free sourcing of certain commodities and products. It requires traceability to origin, risk assessment, and mitigation actions before goods can enter or leave the EU market.
- CSRD is about sustainability reporting. It requires large companies to disclose environmental, social, and governance (ESG) impacts, risks, and targets, including issues like deforestation or land use, if material to their operations. The data required for EUDR can help feed into CSRD disclosures.
- CSDDD introduces a broader due diligence duty for human rights and environmental harms across global value chains. While EUDR is product-specific and mandatory for market access, CSDDD is company-wide and focuses on corporate governance and liability. It reinforces the importance of a comprehensive due diligence framework, including deforestation risk.
Although each regulation has a different scope, they all push toward the same outcome: greater corporate responsibility and transparency. The EU has signaled that companies may be able to reuse information and reports across frameworks, especially for due diligence processes that overlap. This will reduce duplication and streamline compliance if companies invest in integrated ESG systems.
Why This Matters for EUDR Implementation
If your company is already preparing for CSRD or CSDDD, you’re not starting from scratch. Systems for supplier mapping, impact assessments, and stakeholder engagement will help with EUDR too, though the requirements for geolocation and deforestation verification are more specific and technical.
On the flip side, if you’re starting with EUDR, it’s smart to build your systems with future reporting and governance in mind. For example:
- Use traceability data that can feed into broader ESG metrics.
- Align your risk scoring models across human rights, climate, and deforestation.
- Integrate internal workflows between compliance, procurement, and sustainability teams.
The smartest companies are already thinking beyond single regulations, investing in scalable infrastructure, supplier engagement strategies, and audit-ready documentation that serves multiple frameworks at once.
Comparison Table
Most Labor-Intensive and Automatable Aspects of EUDR
One of the most common questions from companies preparing for EUDR is, where should we focus human effort, and where can tech help? The reality is that EUDR compliance requires both human and digital capacity. Some parts of the process are well-suited to automation; others still rely heavily on human relationships, judgment, and boots-on-the-ground coordination, especially when working with smallholders or fragmented supply chains.
Below is a breakdown of the most labor-intensive vs. automatable elements of EUDR compliance:
Labor-Intensive (Human-Led or High-Touch)
These tasks often require direct supplier engagement, contextual understanding, or local presence:
- Supplier onboarding and engagement
- Educating suppliers about EUDR requirements
- Helping smallholders gather geolocation data or legal documentation
- Translating regulatory language into local action
- Risk mitigation planning
- Developing alternative sourcing strategies
- Creating improvement plans for high-risk suppliers
- Conducting supplier audits or field visits
- Contextual risk analysis
- Interpreting land tenure issues, corruption risks, or indigenous rights
- Evaluating data quality and red flags that automation might miss
- Internal coordination and alignment
- Breaking silos between procurement, legal, ESG, and IT teams
- Building company-wide ownership of the due diligence process
- Change management
- Embedding EUDR compliance into procurement policies and contracts
- Upskilling internal teams and shifting mindsets around sustainability and risk
Automatable (Digital or Tool-Supported)
These areas can be supported or streamlined using existing technologies:
- Geolocation data collection and mapping
- Using satellite tools, mobile GPS apps, or traceability platforms
- Auto checking the deforestation status of farm plots
- Risk scoring and benchmarking
- Centralized tools that assign risk levels based on country, supplier history, or certification status
- Integration with the EU’s upcoming country benchmarking data
- Due diligence statement creation and tracking
- Generating and submitting digital statements
- Linking documents and product batches to EU submission systems
- Recordkeeping and audit preparation
- Storing due diligence files, mapping outputs, and verification evidence
- Creating automated alerts for missing or expiring data
- Data integration
- Syncing sourcing data with ERP or supplier management systems
- Building dashboards for internal compliance visibility
Finding the Right Balance
Many companies are opting for a “tech + touch” model, where automation handles data-heavy tasks and people focus on relationship-building and contextual judgment. Tools can reduce administrative burdens, but they can’t replace human understanding, especially when working with vulnerable suppliers or navigating complex risk environments.
The takeaway? Start with the hardest-to-automate parts first. This typically involves engaging with your suppliers, aligning your internal teams, and developing your risk assessment framework. Once those are in place, digital solutions can help scale and sustain your efforts.
Implementation Roadmap: How to Get Yourself Ready
Complying with the EUDR isn’t a one-click process; it’s a transformation of how companies map, monitor, and manage their supply chains. For many businesses, it means building new capabilities across procurement, ESG, and compliance teams. Whether you’re just starting or already halfway through, having a clear roadmap is essential.
Here’s a step-by-step implementation plan, based on best practices from sustainability consultants, platforms like osapiens, and The Overview Effect’s own support model:
Step 1: Build Internal Awareness and Ownership
- Create a cross-functional team including procurement, compliance, legal, ESG, and IT.
- Map out how EUDR overlaps with other priorities like CSRD, due diligence, and digital transformation.
- Educate leadership: EUDR isn’t just a sustainability issue; it’s a legal and operational one.
Step 2: Map Your Exposure
- Identify which of your products fall under EUDR using HS codes from Annex I.
- Break down product compositions to understand if and where regulated commodities are used (even as derivatives).
- Identify suppliers and sourcing countries that fall into the value chain for those products.
Step 3: Assess Your Readiness
- Evaluate how much supply chain visibility you currently have.
- Determine whether you already collect any geo-coordinates, traceability data, or legality documentation.
- Identify gaps in systems, capacity, and supplier relationships.
Step 4: Design Your Due Diligence Process
- Choose how you’ll collect data: GPS field apps, traceability platforms, supplier questionnaires, or a mix.
- Develop your risk assessment model and define what triggers risk mitigation.
- Document everything in a way that aligns with both EUDR and future audit needs.
Step 5: Select Tools That Fit
- Choose software that matches your internal systems and the complexity of your supply chain.
- Look for platforms that can:
- Handle geo-data
- Automate risk scoring
- Generate due diligence statements
- Support audit trails
- Don’t forget the human side: ensure teams are trained to use new tools effectively.
Step 6: Engage Your Suppliers
- Start early, especially with smallholders or suppliers in high-risk regions.
- Provide training, templates, and tools where possible.
- Focus on collaboration, not just compliance. Sustainable change comes from shared understanding and incentives.
Step 7: Pilot, Review, and Scale
- Run a pilot on one product line or commodity to test your approach.
- Review what worked and what didn’t. Capture lessons before scaling to your full portfolio.
- Prepare your team for the December 2025 or June 2026 deadline, depending on company size.
Bonus Tip: Don’t Go It Alone
Consider working with external advisors or tech partners with EUDR experience. They can help accelerate traceability mapping, assess tool fit, and provide hands-on support through audits or risk reviews. Joining peer communities (like those hosted by The Overview Effect or industry groups) can also give you access to shared learning, supplier benchmarks, and real-world strategies.
Conclusion:
The EUDR marks a new chapter in how the EU and the companies trading with it approach global supply chains. It’s no longer enough to say a product is “sustainable” or “certified.” Businesses now need to prove, with traceable data and risk analysis, that their products are deforestation-free, legally produced, and responsibly sourced.
Yes, the regulation introduces new complexity. It requires system upgrades, supplier engagement, and cross-departmental alignment. But it also creates an opportunity: to build smarter, more resilient supply chains that can stand up to growing scrutiny from regulators, investors, and customers.
Whether you’re importing coffee, selling leather goods, or sourcing soy-based animal feed, the EUDR is a call to action. It’s a chance to move from reactive compliance to proactive leadership, where supply chain transparency isn’t just about avoiding penalties but about building trust, unlocking value, and doing business in a way that respects people and the planet.
How The Overview Effect Can Help
At The Overview Effect, the Digital vertical and sister company Data for Better [link on both] combine systems thinking, hands-on implementation experience, and deep sustainability expertise to help companies move from uncertainty to action. If you’re not sure where to start, you’re not alone. Many companies are still trying to figure out which products are in scope, what data is missing, or whether their current systems are ready for traceability and due diligence.
That’s why Digita and Data For Better offer a focused EUDR Readiness Assessment designed to help you get clear before you commit. Our task force works with companies to assess their EUDR exposure, scan for risk, review readiness, and define next steps. No fluff. No vendor pushes. Just honest advice.
You can choose between two formats:
- Light Assessment – A quick, strategic review with a short roadmap
- Full Assessment – A detailed scan of supply chain exposure, tooling, data gaps, and governance fit, including executive briefing
Whether you’re navigating EUDR for the first time or fine-tuning your compliance strategy, we bring both technical expertise and practical implementation experience. We’re tool-agnostic, fast, and focused on making sustainability work in the real world.
Reference list:
- European Commission (2023) Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation. Official Journal of the European Union. Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1115 (Accessed: 19 May 2025).
- European Parliament (2022) Deforestation: causes and how the EU is tackling it. European Parliament News. Available at: https://www.europarl.europa.eu/topics/en/article/20221019STO44561/deforestation-causes-and-how-the-eu-is-tackling-it (Accessed: 19 May 2025).
- Forest Declaration Assessment Partners (2023) Off track and falling behind: Tracking progress on 2030 forest goals. Climate Focus (coordinator and editor). Available at: https://forestdeclaration.org (Accessed: 20 May 2025).
- LiveEO (2024) The road to EUDR: Key dates and milestones in the EU’s deforestation regulation. Available at: https://www.live-eo.com/article/the-road-to-eudr-key-dates-and-milestones-in-the-eus-deforestation-regulation#implementation-and-enforcement (Accessed: 20 May 2025).
- Osapiens (2024) Navigating the EU Deforestation Regulation: A Comprehensive Guide to Compliance Preparation for EUDR. White Paper. Mannheim: osapiens GmbH.
- The Overview Effect (2024) What You Need To Know About The European Deforestation Regulation (EUDR). PDF resource. Amsterdam: The Overview Effect.
- Tony’s Chocolonely (2025) Our promise. Available at: https://tonyschocolonely.com/pages/our-promise (Accessed: 29 May 2025).
- WWF EU (2021) ‘EU consumption responsible for 16% of tropical deforestation linked to international trade – new report’. WWF EU Newsroom, 14 April. Available at: https://www.wwf.eu/?2831941/EU-consumption-responsible-for-16-of-tropical-deforestation-linked-to-international-trade (Accessed: 19 May 2025).
Appendices
Annex I Summary Table: Included Commodities and their derived products
| Commodity | Products |
| Cattle | · Live cattle · Meat of cattle, fresh or chilled · Meat of cattle, frozen · Edible offal of cattle, fresh or chilled · Edible cattle livers, frozen · Edible cattle offal (excluding tongues and livers), frozen · Other prepared or preserved meat, meat offal, blood, of cattle · Raw hides and skins of cattle (fresh, or salted, dried, limed, pickled or otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not dehaired or split · Tanned or crust hides and skins of cattle, without hair on, whether or not split, but not further prepared · Leather of cattle, further prepared after tanning or crusting, including parchment-dressed leather, without hair on, whether or not split, other than leather of heading 4114 |
| Cocoa | · Cocoa beans, whole or broken, raw or roasted · Cocoa shells, husks, skins and other cocoa waste · Cocoa paste, whether or not defatted · Cocoa butter, fat and oil · Cocoa powder, not containing added sugar or other sweetening matter · Chocolate and other food preparations containing cocoa |
| Coffee | · Coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee in any proportion |
| Oil Palm | · Palm nuts and kernels · Palm oil and its fractions, whether or not refined, but not chemically modified · Crude palm kernel and babassu oil and fractions thereof, whether or not refined, but not chemically modified · Palm kernel and babassu oil and their fractions, whether or not refined, but not chemically modified (excluding crude oil) · Oilcake and other solid residues of palm nuts or kernels, whether or not ground or in the form of pellets, resulting from the extraction of palm nut or kernel fats or oils · Glycerol, with a purity of 95 % or more (calculated on the weight of the dry product) · Palmitic acid, stearic acid, their salts and esters · Saturated acyclic monocarboxylic acids, their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulphonated, nitrated or nitrosated derivatives (excluding formic acid, acetic acid, mono-, di- or trichloroacetic acids, propionic acid, butanoic acids, pentanoic acids, palmitic acid, stearic acid, their salts and esters, and acetic anhydride) · Stearic acid, industrial · Oleic acid, industrial · Industrial monocarboxylic fatty acids; acid oils from refining (excluding stearic acid, oleic acid and tall oil fatty acids) · Industrial fatty alcohols |
| Rubber | · Natural rubber, balata, gutta-percha, guayule, chicle and similar natural gums, in primary forms or in plates, sheets or strip · Compounded rubber, unvulcanised, in primary forms or in plates, sheets or strip · Unvulcanised rubber in other forms (e.g. rods, tubes and profile shapes) and articles (e.g. discs and rings) · Vulcanised rubber thread and cord · Plates, sheets, strips, rods and profile shapes, of vulcanised rubber other than hard rubber · Conveyer or transmission belts or belting, of vulcanised rubber · New pneumatic tyres, of rubber · Retreaded or used pneumatic tyres of rubber; solid or cushion tyres, tyre treads and tyre flaps, of rubber · Inner tubes, of rubber · Articles of apparel and clothing accessories (including gloves, mittens and mitts), for all purposes, of vulcanised rubber other than hard rubber · Other articles of vulcanised rubber other than hard rubber, not elsewhere specified in chapter 40 · Hard rubber (e.g. ebonite) in all forms including waste and scrap; articles of hard rubber |
| Soya | · Soya beans, whether or not broken · Soya bean flour and meal · Soya-bean oil and its fractions, whether or not refined, but not chemically modified · Oilcake and other solid residues, whether or not ground or in the form of pellets, resulting from the extraction of soya-bean oil |
| Wood | · Fuel wood, in logs, in billets, in twigs, in faggots or in similar forms; wood in chips or particles; sawdust and wood waste and scrap, whether or not agglomerated in logs, briquettes, pellets or similar forms · Wood charcoal (including shell or nut charcoal), whether or not agglomerated · Wood in the rough, whether or not stripped of bark or sapwood, or roughly squared · Hoopwood; split poles; piles, pickets and stakes of wood, pointed but not sawn lengthwise; wooden sticks, roughly trimmed but not turned, bent or otherwise worked, suitable for the manufacture of walking sticks, umbrellas, tool handles or the like; chipwood and the like · Wood wool; wood flour · Railway or tramway sleepers (cross-ties) of wood · Wood sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness exceeding 6 mm · Sheets for veneering (including those obtained by slicing laminated wood), for plywood or for other similar laminated wood and other wood, sawn lengthwise, sliced or peeled, whether or not planed, sanded, spliced or end-jointed, of a thickness not exceeding 6 mm · Wood (including strips and friezes for parquet flooring, not assembled) continuously shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, moulded, rounded or the like) along any of its edges, ends or faces, whether or not planed, sanded or end-jointed · Particle board, oriented strand board (OSB) and similar board (for example, waferboard) of wood or other ligneous materials, whether or not agglomerated with resins or other organic binding substances · Fibreboard of wood or other ligneous materials, whether or not bonded with resins or other organic substances · Plywood, veneered panels and similar laminated wood · Densified wood, in blocks, plates, strips or profile shapes · Wooden frames for paintings, photographs, mirrors or similar objects · Packing cases, boxes, crates, drums and similar packings, of wood; cable-drums of wood; pallets, box pallets and other load boards, of wood; · pallet collars of wood · (not including packing material used exclusively as packing material to support, protect or carry another product placed on the market) · Casks, barrels, vats, tubs and other coopers’ products and parts thereof, of wood, including staves · Tools, tool bodies, tool handles, broom or brush bodies and handles, of wood; boot or shoe lasts and trees, of wood · Builders’ joinery and carpentry of wood, including cellular wood panels, assembled flooring panels, shingles and shakes · Tableware and kitchenware, of wood · Wood marquetry and inlaid wood; caskets and cases for jewellery or cutlery, and similar articles, of wood; statuettes and other ornaments, of wood; wooden articles of furniture not falling in Chapter 94 · Other articles of wood · Pulp and paper of Chapters 47 and 48 of the Combined Nomenclature, with the exception of bamboo-based and recovered (waste and scrap) products · Printed books, newspapers, pictures and other products of the printing industry, manuscripts, typescripts and plans, of paper · Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof, of wood · Wooden furniture, and parts thereof · Prefabricated buildings of wood |
Annex II Due Diligence Requirements & Format
Due diligence statement
Information to be contained in the due diligence statement in accordance with Article 4 (2):
| 1. | Operator’s name, address and, in the event of relevant commodities and relevant products entering or leaving the market, the Economic Operators Registration and Identification (EORI) number in accordance with Article 9 of Regulation (EU) No 952/2013. |
| 2. | Harmonised System code, free-text description, including the trade name as well as, where applicable, the full scientific name, and quantity of the relevant product that the operator intends to place on the market or export. For relevant products entering or leaving the market, the quantity is to be expressed in kilograms of net mass and, where applicable, in the supplementary unit set out in Annex I to Regulation (EEC) No 2658/87 against the indicated Harmonised System code or, in all other cases, expressed in net mass specifying a percentage estimate or deviation or, where applicable, volume or number of items. A supplementary unit is applicable where it is defined consistently for all possible subheadings under the Harmonised System code referred to in the due diligence statement. |
| 3. | Country of production and the geolocation of all plots of land where the relevant commodities were produced. For relevant products that contain or have been made using cattle, and for such relevant products that have been fed with relevant products, the geolocation shall refer to all the establishments where the cattle were kept. Where the relevant product contains or has been made using commodities produced in different plots of land, the geolocation of all plots of land shall be included in accordance with Article 9(1), point (d). |
| 4. | For operators referring to an existing due diligence statement pursuant to Article 4 (8) and (9), the reference number of such due diligence statement. |
| 5. | The text: ‘By submitting this due diligence statement, the operator confirms that due diligence in accordance with Regulation (EU) 2023/1115 was carried out and that no or only a negligible risk was found that the relevant products do not comply with Article 3, point (a) or (b), of that Regulation.’. |
| 6. | Signature in the following format: ‘Signed for and on behalf of: Date: Name and function: Signature:’. |