As organisations across Europe prepare for stricter expectations on responsible sourcing, the EU Deforestation Regulation (EUDR) has become a defining component of corporate sustainability. Despite discussion around a potential delay, the legislation remains a major regulatory milestone for any business handling forest-risk commodities.
However, many companies are still unsure where to begin, how deeply the EUDR regulation will affect their operations, and what practical steps are required to stay ahead of the 2026 enforcement timeline. The guide below offers a structured pathway to understanding EUDR compliance, outlining the essential steps you must take to prepare with confidence.
What is EUDR, and who does it apply to?
The Regulation (EU) 2023/1115 on deforestation-free products, commonly referred to as the EU Deforestation Regulation (EUDR), was designed to ensure that certain commodities placed on or exported from the European Union do not originate from land that was deforested or degraded after 31 December 2020.
Its formal entry into force was 29 June 2023, with obligations on businesses coming into effect from 30 December 2025 for large and medium-sized operators (and later for smaller enterprises) under transitional arrangements. The EUDR applies to operators and traders who place relevant products (derived from specified “forest-risk” commodities) on the EU market or export them from it.
These covered commodities include: cattle, cocoa, coffee, oil palm, rubber, soy and wood (and many products derived from them, such as furniture, leather, chocolate, pulp, paper) under the EUDR regulation. In practical terms, if your organisation sources or trades any of these commodities (or products derived from them) and has exposure (directly or via your supply chain) to the EU market, you must treat the EUDR as a priority regulatory obligation.
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Step 1: Map your supply chain
Begin by developing a robust supply-chain map for all goods and input materials derived from or containing EUDR commodities. This means identifying where each commodity in scope originates, tracing upstream to the producer or supplier region, and recording key details such as geolocation, land‐use history, and transformation stages.
Effective supply-chain mapping brings two major benefits: it gives visibility to where deforestation or forest-degradation risk may lie and enables you to identify which suppliers fall under the EUDR-regulation obligations. Without mapping, all subsequent steps (risk assessment, verification, monitoring) become inherently weaker.
In your mapping effort, ensure you cover:
- All relevant suppliers and intermediaries
- The commodity flows (including derived products)
- Timestamps or production years (to test the “post-31 December 2020” cutoff)
- Links to the full spectrum of EUDR commodities (cattle, cocoa, coffee, oil palm, rubber, soy, wood).
This preparatory work is foundational to achieving EUDR compliance.
Step 2: Assess risk of non-compliance
Once you have mapped your supply chain, the next step is a structured risk assessment. Under the EUDR regime, businesses must evaluate whether their products may be linked to deforestation or forest degradation, or to breaches of relevant laws in the country of origin.
Your risk assessment should consider:
- Geographic risk: Is the production region a “high-risk” or “standard-risk” area for deforestation?
- Supplier risk: Does the supplier have weak governance, opaque supply-chain practices, or known land-use controversies?
- Commodity risk: Some commodities (e.g., cattle or soy) are historically associated with higher deforestation rates.
- Production timeframe risk: Did land-use conversion after 31 December 2020 occur?
By systematically assessing these dimensions, you can classify each supply-chain link by level of risk and prioritise your mitigation efforts accordingly.
Step 3: Engage with suppliers
Effective supplier engagement is critical to transforming risk into a manageable opportunity. Under the EUDR legislation, operators are expected to collaborate with suppliers to understand sourcing practices, secure geolocation data, and build transparency mechanisms.
Key actions in this step include:
- Communicating your EUDR-compliance expectations to all relevant suppliers, including derived product makers and secondary tier suppliers.
- Requesting and collecting geolocation or polygon-level coordinates of production plots (as required under EUDR).
- Establishing contractual or preferred-supplier provisions that require production compliance with relevant laws and deforestation-free criteria.
- Supporting capacity building for suppliers who may lack technical resources (especially in regions with smallholder farming).
This step helps you build stronger upstream relationships and fosters supply-chain resilience ahead of the regulation’s full enforcement.
Step 4: Strengthen internal systems
Internal systems and governance mechanisms are the backbone of compliance. For the EUDR regime, this means embedding due diligence procedures, internal controls, record-keeping, and training across your organisation.
Your internal system development should address:
- A due diligence policy specific to EUDR, aligned with your broader sustainability strategy.
- Clear roles and responsibilities for managing EUDR-related processes (e.g., sourcing team, compliance/legal, procurement).
- Data-management systems capable of handling geolocation data, supplier audits, and traceability records.
- Training for procurement teams and relevant functions on EUDR requirements, risk indicators, and reporting obligations.
Strong internal systems ensure you are proactively managing the “who, what, where and when” of EUDR compliance, rather than reacting when regulatory deadlines loom.
Step 5: Monitor and verify
EUDR compliance is not a one-off exercise; it demands ongoing monitoring and verification. You’ll need to monitor the supply chain to ensure continuous compliance with the deforestation-free requirement (i.e., no deforestation or degradation after 31 December 2020) and keep updated evidence of supplier compliance with relevant production-country laws.
Key monitoring & verification tools include:
- Supplier audits or third-party verification of produced commodities and derived products.
- Use of satellite imagery, remote sensing, or geolocation verification to confirm no land-use conversion.
- Periodic review of supplier risk profiles (geography, commodity, governance) and triggering escalation where risk increases.
- Documentation of corrective actions with suppliers when non-compliance or risk is identified.
These steps place you in a strong position to demonstrate supply-chain integrity, audit-readiness and responsiveness, all central to EUDR obligations.
Step 6: Communicate and document compliance
Finally, you must communicate and document your compliance efforts. Under the EUDR regulation, operators are required to submit a due diligence statement when placing relevant products on the EU market or exporting them.
Your documentation strategy should include:
- Preparing a formal due diligence statement that covers supplier mapping, risk assessment, and steps taken to mitigate risks.
- Maintaining full records (geolocation, supplier declarations, audit reports, monitoring logs) for the required retention period.
- Communicating to internal stakeholders and senior leadership about EUDR obligations, progress and risks.
- Publishing externally (where appropriate) a summary of how your organisation is meeting EUDR compliance – this strengthens market credibility and supports client/investor confidence.
By documenting clearly and communicating appropriately, you align with the transparency expectations of the EUDR legislation, demonstrate due diligence and reduce regulatory, reputational and market risk.
Conclusion
The EUDR introduces a new level of scrutiny to global supply chains, reshaping how organisations approach sourcing, traceability, and risk management. Meeting the 2026 requirements will require collaboration with suppliers, investment in internal systems, and a long-term commitment to corporate sustainability.
By taking a structured approach to mapping, assessing, engaging, monitoring, and documenting, businesses can meet the EUDR legislation with confidence but also strengthen resilience, enhance transparency, and build trust with customers and stakeholders.
If you’re looking to close capability gaps and strengthen your organisation’s compliance readiness, now is the time to act. Our sustainability training for employees builds the practical, business-focused expertise required to navigate EUDR compliance and the wider ESG landscape with confidence.
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Dedicated to harnessing the power of storytelling to raise awareness, demystify, and drive behavioural change, Bronagh works as the Communications & Content Manager at the Institute of Sustainability Studies. Alongside her work with ISS, Bronagh contributes articles to several news media publications on sustainability and mental health.
- Bronagh Loughlinhttps://instituteofsustainabilitystudies.com/insights/author/bronagh/
- Bronagh Loughlinhttps://instituteofsustainabilitystudies.com/insights/author/bronagh/
- Bronagh Loughlinhttps://instituteofsustainabilitystudies.com/insights/author/bronagh/
- Bronagh Loughlinhttps://instituteofsustainabilitystudies.com/insights/author/bronagh/








