With the EUDR, the EU wants to ensure that products in Europe do not contribute to deforestation. To this end, companies must know and prove exactly where their materials come from, right down to the exact location of the cultivation areas, and provide this evidence before sale. For purchasing, this means asking suppliers clear questions, collecting data in a transparent manner, and establishing simple, regulated processes so that everything can be verified.

EUDR in brief

According to the European Commission, the EUDR Regulation on deforestation-free products is intended to ensure that listed products purchased, used, and consumed in the EU do not contribute to deforestation or forest degradation in the EU or worldwide. At the same time, CO₂ emissions caused by EU consumption and production of the raw materials covered are to be reduced by at least 32 million tons per year. The rules address all deforestation-driving agricultural expansion within the scope of application as well as forest degradation.

Background                                                                                                

The EUDR came into force on June 29, 2023. The main driver of deforestation is the expansion of agricultural land for raw materials such as cattle, wood, cocoa, soy, palm oil, coffee, and rubber, as well as their derived products, such as leather, chocolate, tires, and furniture. Operators and traders who place these raw materials or products on the market in the EU or export them from the EU must prove that they do not originate from recently deforested areas and have not contributed to forest degradation.

List of industries affected:

• Food & beverages (beef, chocolate/cocoa, coffee, products containing palm oil)
• Wood & furniture (including construction/interior design with wood)
• Paper, cardboard & printed matter
• Tires & rubber products (automotive/transport)
• Fashion/shoes & leather goods
• Animal feed; animal husbandry (soy-based)
• Retail/private labels as importers

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Relationship to the EUTR

The EUDR repeals the EU Timber Regulation (EUTR). However, for timber products manufactured before June 29, 2023, the EUTR will continue to apply until December 31, 2027. For other products and for timber produced after the EUDR enters into force, the EUTR will be repealed when the EUDR becomes applicable.

Start of application & transitions

In December 2024, an additional 12-month introductory phase was decided upon. This means that the EUDR will apply to large and medium-sized enterprises from December 30, 2025, and to micro and small enterprises from June 30, 2026.

Implementation & Assistance

The Commission provides guidance (latest version April 2025, available in all languages) and other resources for implementation. Member States shall designate one or more competent authorities to carry out the tasks arising from the Regulation. Since April 2025, the Commission has introduced simplifications to facilitate implementation. These include, among other things, a risk classification of countries by means of an implementing regulation. In addition, a consultation was held on a delegated act intended to further simplify and clarify the scope and application.

Further simplification measures by the Commission:

• Large companies can reuse existing due diligence statements for re-imports.
• An authorized representative can submit a due diligence statement on behalf of members of corporate groups.
• Companies can submit annual due diligence statements instead of delivery/batch-related ones.
• Large downstream companies benefit from simplified obligations: they must collect reference numbers from their suppliers' due diligence statements and use these references for their own statements.

Governance & Exchange

The Commission operates a multi-stakeholderplatform on forest protection and restoration, where MemberStates, selected stakeholders (in particular business and industry associations and NGOs) and third countries exchange information on work progress and best practices. Minutes, agendas and documents are publicly available; a list of member organisations is available. In addition, an EU observatory on deforestation and forest degradation is beingset up, building onexisting monitoring tools (including Copernicus) and providing freely accessible maps and data sets on forest change and its drivers.

Team Europe Initiative

As part of the Team Europe Initiative for deforestation-free value chains, the EU is supporting partner countries in their transition tosustainable, deforestation-free, and legal agricultural supply chains, in linewith the Global Gateway Strategy. The initiative is being implemented jointly with member states (including Germany, the Netherlands, and France) and isstarting with a financial package of €70 million.

IT system

The EUDR information system pursuant to Article 33 was launched on December 4, 2024. Registration for users has beenopen since November 2024.

Materials

The Commission provides extensive publications, including FAQs,a myth buster, fact sheets (also specifically for SMEs andsmall farmers), guidance documents (e.g., for companies in the cocoasupply chain), lists of competent authorities, briefing notes, anddocuments on impact assessments and evaluations of existing legislation.

Impact of the EUDR on purchasing

The EUDR makes purchasing significantly more data- and evidence-driven. Affected goodsmay only enter the EU if their origin and legality can be proven for each individual shipment. Thisnoticeably changes priorities, timings, and the selection of suppliers.

Assortment & Sourcing: Categories such as beef, wood, cocoa, soy, palm oil, coffee, and rubber (includingderivatives) are coming into focus. Countries of origin and growing regions arebecoming key selection criteria.

Supplier relationships: Suppliers must provide precise origin data (including geocoordinates) and evidence. Thosewho cannot do so will lose competitiveness, which may lead to portfoliochanges.

Tenders & prices: More obligations in RFI/RFQ lead to longer lead times; additional expenses for data,audits, and documentation can influence prices.

Contracts & responsibility: Purchasing contracts need clear commitments regarding data provision,inspection, and rectification rights. Internally, there must be clearresponsibilities between purchasing, quality, sustainability, legal, and IT.

Risk & controls: Country benchmarking and risk-based government audits increase the pressure forreliable evidence. Missing or incorrect information jeopardizes market accessand can result in sanctions.

Data & evidence: End-to-enddocumentation is becoming mandatory, from supplier to delivery. References anddeclarations must be traceable and verifiable (including electronic submissionin the EU system).

Planning & timing: More time required for data collection and audits affects procurement cycles, orderpoints, and buffer stocks. Early involvement of suppliers becomes a successfactor.

Practice: EUDR implementation in 6 steps

1. Inventory of EUDR-relevant goods

Before getting started, purchasing departments should clarify: Which parts of purchasing fall under the EUDR and where do you need to take action first?

Here's how to do it:

• Collect products and derivatives: beef, wood, cocoa, soy, palm oil, coffee, rubber, and products made from them (e.g., leather goods, furniture, chocolate, tires, paper).
• Compile data: HS codes (Harmonized System for commodity number/customs tariff classification), annual quantities, main suppliers, countries/regions of origin.
• Check cut-off: Look at inventories and production dates (what falls within the EUDR period?).
• Set priorities: Start where sales/volume are high, risk is increased, or the chain is complex.

What this means for purchasing:

• Expect longer lead times (request data, clarify queries).
• Plan a budget for data collection and possible audits.
• Get everyone involved early on: quality, sustainability, legal, IT.

The result:
A clear, easy-to-understand overview: Which categories, countries, and suppliers are EUDR-critical, plus a starting list for phase 1 (e.g., top 10 suppliers/countries) that you can use to get started right away.

2. Supplier mapping & geodata

This is where it is decided whether your EUDR evidence is valid: you need verifiable data on origin down to the parcel level that is accurate, complete, and traceable.

This is how you take the step:

• Questionnaires with mandatory fields: product, quantity, harvest/production period, GPS coordinates per area (for large areas as a polygon = outline), parties involved, proof of legality (e.g., land use rights).
• Automatic check: Completeness, format (decimal degrees), plausibility (is the area in the right country/region?), duplicates. Break down mixed batches and document each individual origin.
• Fill in gaps: Satellite images (e.g., freely available services), additional location evidence, independent confirmation from the supplier.

What this means for purchasing:

Suppliers without reliable geodata lose competitiveness and portfolio adjustments may be necessary. Tenders become more extensive. Purchasing should allow more lead time for responses and queries.

Result of this step:
A complete data set with approved geodata is available for each supplier and each delivery, forming the basis for risk assessment, DDS, and subsequent submission to the EU system.

3. Risk scoring

Before a product is allowed onto the EU market, a traceable assessment must be carried out for each delivery. The aim is to achieve a "negligible risk" result, clearly justified and documented.

Define criteria:

• Country/region status from the EU benchmark
• Proximity to protected areas
• Current deforestation around the geocoordinates
• Length/transparency of the supply chain
• Quality/completeness of documentation
• Respect for the rights of affected parties, e.g., FPIC -> (Free, Prior and Informed Consent, which describes the right of indigenous peoples and local communities to decide on land use in their areas)
• Legal framework in the country of origin.

Apply assessment:
A traffic light or point scale (e.g., 0–100) can be used, and the results and reasons for each delivery can be documented directly in the data record.

Define escalation:
Set clear thresholds:

Green = negligible → approve

Yellow = Improvement required → Request additional evidence

Red = high → check audit/source change

Impact on purchasing

Authorities conduct risk-based checks. If the data is incomplete or unclear, delays and additional costs may arise. Necessary additional checks such as expert opinions or audits often have a direct impact on prices and delivery times. This should be taken into account in negotiations and scheduling.

Result of this step
A clearly documented assessment for each delivery: "negligible" (approval) or transfer to risk mitigation & contracts for targeted measures.

4. Mitigation & Contracts

If the review reveals more than a negligible risk, action must be taken, with clear evidence, fixed deadlines, and, if necessary, new sources of supply. The aim is to visibly reduce the risk or consistently switch to alternative suppliers.

Procedure:

• equest additional evidence: e.g., current satellite images, independent expert opinions, or on-site audits.
• Agree on an action plan: concrete steps with deadlines and KPIs (who delivers what by when; when to review again).
• Prepare to change sourcing: if evidence is not provided or the risk is not reduced.
• Update contracts: obligations to provide data, inspection/audit rights, remedial measures, termination in the event of violations, and rules on costs and subsequent performance.

Impact on purchasing
Clearer service descriptions and service levels in contracts create binding commitments. Defined deadlines for providing evidence make timing more predictable and reduce surprises in terms of deadlines and prices.

Result
Either the status "negligible risk" is achieved, and the delivery is approved accordingly, or the supplier is replaced and EUDR compliance is maintained.

5. Evidence management

Now comes the part that saves time, nerves, and money in the event of an audit. All evidence must be stored in such a way that it can be found and exported at any time. The goal is to have documentation that shows at the touch of a button where the goods come from, what tests have been carried out, and which delivery everything belongs to.

Procedure

• Central, versioned storage with clear assignment to the delivery (e.g., by reference number).
• Uniform file names and metadata, fixed retention periods, and access and role rights.
• Ready-made export packages for controls: geodata, documents proving legality, risk report, and all references in one bundle.

Impact on purchasing
Less search time, faster response to government inquiries, and a significantly lower risk of delays or fines.

Result of this step
A single source of truth for each delivery, which can be exported as a package immediately if required.

6. DDS in TRACES

Before goods can be placed on the market, a digital declaration of delivery is required. The declaration must be completed correctly and submitted on time.

DDS (Declaration of Diligence): Confirms that a specific shipment complies with the EUDR. Without a DDS, the goods cannot be placed on the market or exported.

TRACES (EUDR information system): EU portal through which the DDS is submitted. TRACES can be submitted via web form, CSV bulk upload, or API. Each DDS is assigned a reference number.

How submission works in practice:

• Define roles & approvals: Who creates, checks, approves? Define the dual control principle.
• Select submission method: Dashboard for individual cases, CSV for many processes, API for continuous operation.
• Check mandatory information: Product/HS code, quantity, time period, geodata, parties involved, risk assessment result (negligible), contact/identification data.
• Ensure reference management: Document the DDS reference number and pass it on to downstream partners (important for re-import/further processing).
• Schedule reviews & KPIs: At least annually, e.g., "time to DDS approval" and "proportion of complete data sets."

This has a direct impact on purchasing: The DDS must be available before marketing/export. Purchasing should therefore plan a buffer for queries and keep an eye on the start dates of December 30, 2025/June 30, 2026.

Avoid typical mistakes:

• Differing HS codes between quotation, contract, and DDS
• Incomplete geodata or missing proof of legality
• Quantities/periods in the DDS do not match the delivery documents

The end result is a submitted DDS with a reference number in TRACES and the delivery is EUDR-ready.

From step-by-step instructions to implementation in the system

So far, it is clear that EUDR is not a single document, but a continuous process for each delivery, from geodata to DDS. In practice, this quickly fails due to email attachments and Excel: mandatory fields are missing, versions get mixed up, deadlines slip, and in the end, the export for TRACES is missing. For EUDR to run reliably in day-to-day business, workflows are needed that automatically ensure data quality, approvals, and evidence.

Modern procurement platforms anchor the six steps "end-to-end":

• RFI/RFQ forms with mandatory logic for HS codes, quantities, geocoordinates, and proof of legality
• Automatic risk scoring based on country status, documentation, and supply chain complexity – with clear escalations
• Evidence repository with versioning, role-based permissions, and dual-control approvals
• Structured exports for fast, error-free DDS submission in TRACES

This makes EUDR a repeatable routine rather than a special project, transparent, auditable, and scalable. Implemented by modern procurement platforms.

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Conclusion

The EUDR is not a one-time form, but an ongoing verification process for each delivery. Those who can prove the origin down to the parcel, transparently assess risks, and submit the DDS cleanly in TRACES secure market access, avoid fines, and gain real transparency in the supply chain. The difference between stress and routine lies in standardized workflows instead of email and Excel.

Those who approach EUDR in a structured manner will reap the benefits: less risk, faster approvals, better data. Modern procurement platforms that embed the steps end-to-end in existing processes can provide support in this regard.