The EU Deforestation Regulation (EUDR) requires companies to prove their products are not linked to deforestation. For procurement and supply chain teams, this means establishing traceability systems, collecting geolocation data, and submitting due diligence statements for every shipment entering the EU market.
This guide breaks down EUDR compliance into actionable steps—covering who needs to comply, what data you need, and how satellite-based verification can automate the process.
What is the EUDR?
The EU Deforestation Regulation is a law that prohibits placing products linked to deforestation on the EU market. It applies to seven commodities—cattle, cocoa, coffee, oil palm, rubber, soya, and wood—plus products derived from them (leather, chocolate, furniture, paper, etc.).
The regulation uses a strict cut-off date: December 31, 2020. Any land converted from forest after this date cannot be used to produce EUDR-regulated commodities for the EU market.
Unlike previous voluntary commitments, EUDR is legally binding. Non-compliance can result in fines up to 4% of EU-based turnover, product seizures, and exclusion from the EU market.
Who Needs to Comply?
EUDR creates two categories of businesses with different obligations:
Operators are companies that first place products on the EU market or export them from the EU. They bear full due diligence responsibility—collecting data, assessing risk, and submitting due diligence statements.
Traders are companies that handle products already on the market. Large traders must perform full due diligence. Small and medium traders can rely on upstream due diligence statements but must keep records and be able to identify suppliers.
If your company imports commodities or derived products into the EU—whether directly or through intermediaries—you likely fall under EUDR scope.
The 7 Regulated Commodities
EUDR applies to these commodities and their derived products:
- Cattle — beef, leather, gelatin
- Cocoa — chocolate, cocoa butter, cocoa powder
- Coffee — roasted coffee, extracts
- Oil palm — palm oil, palm kernel oil, oleochemicals
- Rubber — tires, latex products
- Soya — soybean oil, soy meal, animal feed
- Wood — timber, furniture, paper, charcoal
The regulation covers the raw commodity plus hundreds of HS codes for derived products. If your supply chain touches any of these, you need a compliance strategy.
Together, these seven commodity categories account for over 130 million hectares of forest loss since 2001. The chart below shows each category’s share of global commodity-driven deforestation.
Compliance Deadlines
The original deadline was December 30, 2024. Following industry concerns about readiness, the EU extended implementation:
- December 30, 2025 — Large and medium enterprises must comply
- June 30, 2026 — Micro and small enterprises must comply
The extension provides additional time to establish traceability systems, but companies should not delay preparation. Due diligence requires supplier engagement, data collection infrastructure, and verification processes that take months to implement.
Due Diligence Requirements
EUDR due diligence has three components:
1. Information Collection
You must collect and maintain data for every shipment:
- Geolocation coordinates — GPS points or polygon boundaries for every plot of land where the commodity was produced
- Production date or date range — when the commodity was harvested or produced
- Quantity and description — what was produced and how much
- Supplier information — identity of all parties in the supply chain
- Legality documentation — proof the product was legally produced under local laws
2. Risk Assessment
Using the collected information, you must assess whether the product poses deforestation risk. Key questions:
- Was there forest cover on this land on December 31, 2020?
- Has any deforestation occurred since the cut-off date?
- Is the land inside a protected area or primary forest?
- Does the country have high deforestation rates?
The EU will publish a country benchmarking system classifying regions as low, standard, or high risk. High-risk origins require enhanced due diligence.
3. Risk Mitigation
If risk is identified, you must take steps to mitigate it—additional verification, supplier engagement, or sourcing changes—before placing the product on the market.
How Satellite Verification Simplifies Compliance
Traditional due diligence relies on supplier questionnaires and audits—methods that are slow, expensive, and dependent on supplier honesty. Satellite-based verification provides independent evidence that doesn’t rely on self-reported data.
Modern land cover analysis uses satellite imagery to detect forest cover changes over time. By comparing current imagery against historical baselines, automated systems can flag post-2020 deforestation at any coordinate within seconds.
Key capabilities for EUDR compliance:
- Deforestation detection — identify tree cover loss after December 31, 2020
- Protected area screening — check proximity to conservation zones
- Primary forest identification — detect undisturbed forest that requires special verification
- Historical time-lapse — visual evidence of land cover changes year-over-year
Platforms like Continuuiti’s LULC+ module automate this analysis, providing instant EUDR risk scoring for any supplier location. Rather than waiting weeks for manual assessments, supply chain teams can screen hundreds of coordinates in minutes.
Step-by-Step Compliance Checklist
Use this checklist to structure your EUDR compliance program:
1. Scope assessment — Identify all products in your portfolio that contain EUDR-regulated commodities or derivatives.
2. Supply chain mapping — Document suppliers back to origin. For each supplier, collect business details and the locations where commodities are produced.
3. Geolocation collection — Obtain GPS coordinates or polygon boundaries for production plots. This is the most challenging step for complex supply chains.
4. Verification infrastructure — Implement tools for deforestation screening. Manual verification doesn’t scale; automated satellite analysis is essential for supply chains with more than a handful of origins.
5. Risk assessment process — Establish procedures to evaluate each shipment against EUDR criteria before it enters the EU market.
6. Due diligence statement submission — Register with the EU Information System and prepare to submit due diligence statements for every regulated shipment.
7. Record keeping — Maintain documentation for at least 5 years. Authorities can request evidence at any time.
Frequently Asked Questions
What happens if I don’t comply with EUDR?
Non-compliance can result in fines up to 4% of EU-based annual turnover, confiscation of products, exclusion from public procurement, and temporary bans on placing products on the EU market.
Does EUDR apply to products already in my inventory?
Products placed on the EU market before the compliance deadline are not subject to EUDR. However, any products placed on or after December 30, 2025 (or June 30, 2026 for SMEs) must have due diligence completed.
How do I get geolocation data from suppliers?
Request GPS coordinates or polygon boundaries directly from suppliers. For complex supply chains, work with certification bodies or traceability platforms that aggregate origin data. Some industries have established data-sharing mechanisms through commodity roundtables.
Can I rely on certifications like FSC or Rainforest Alliance for EUDR compliance?
Certifications can support your due diligence but don’t replace it. EUDR requires you to perform your own risk assessment using geolocation data. However, certified suppliers often have better traceability infrastructure, making data collection easier.
What if my supply chain has thousands of smallholder farmers?
Complex supply chains require scalable verification solutions. Satellite-based screening can assess risk across thousands of coordinates automatically. For aggregated sourcing (cooperatives, collection points), you need geolocation for each contributing plot, though some simplified due diligence may apply for low-risk countries.
Next Steps
EUDR compliance requires preparation across procurement, legal, and sustainability functions. Start by mapping your exposure—which products, which suppliers, which origins—then build the data collection and verification infrastructure to support ongoing due diligence. Companies should also be aware that the CSDDD (Corporate Sustainability Due Diligence Directive) broadens the EU’s due diligence requirements beyond deforestation, covering human rights and environmental impacts across entire value chains. For companies subject to both directives, see CSDDD vs EUDR: how they compare.
For supply chain teams managing multiple origins, automated satellite verification eliminates the bottleneck of manual assessment. Tools that provide instant deforestation screening, protected area checks, and historical land cover analysis make compliance scalable—even for complex global supply chains.
