What EUDR actually asks of you

Most of what is written about the EU Deforestation Regulation is either a law firm summarising the text or a software vendor selling a dashboard. Neither tells you what changes on the day you place an order. So here is the short version.

The obligation is yours, not your supplier's

This is the part people miss. EUDR puts the duty on whoever places the product on the EU market. If you import cocoa, that is you. Your supplier can send you a signed declaration saying everything is fine, and that declaration is worth very little if a competent authority asks you to prove it. You cannot contract this risk away by getting someone else to sign something.

What counts as evidence

Three things, in practice. Geolocation coordinates for the plots the material came from. Evidence that harvesting was legal under the producing country's own law. And a risk assessment showing you looked at whether those first two are credible.

Coordinates are the sticking point. For a large estate this is straightforward. For a crop like cocoa, where a single container might combine output from hundreds of smallholdings, it is a genuine piece of work. If a supplier offers you EUDR-compliant material and cannot produce plot data, they are not offering you EUDR-compliant material.

Which commodities are caught

Cattle, cocoa, coffee, oil palm, rubber, soya and wood. Then the products derived from them, which is where it catches people out. Palm-derived emulsifiers in a cosmetic formulation are in scope. So is the leather in a finished product, and the packaging if it is wood-based.

If you sell a finished product into the EU, work backwards through your ingredient list rather than assuming this is only about raw cargo.

The deadline that matters

The cut-off is 31 December 2020. Material from land deforested after that date cannot be placed on the EU market, regardless of whether the deforestation was legal where it happened. Legality and deforestation-free are two separate tests and you have to pass both.

What to do before your next order

• List the commodities you buy and mark which fall in scope, including derived products.
• Ask each supplier for plot-level geolocation data, not a declaration. See what actually comes back.
• Where a supplier cannot provide it, qualify an alternative before you need one rather than after.
• Keep the due diligence statement reference number with the shipment record. That is what you will be asked for.

None of this is exotic. It is mostly a matter of asking earlier than feels necessary, because the answer takes longer to get than you expect.