EUDR compliance: the essential guide
Book a demoThe EUDR will enter into application on 30 December 2026 for large and medium-sized companies, and on 30 June 2027 for micro and small operators.
What makes this law different?
The EU regulation on deforestation-free products (EUDR) establishes due diligence requirements to reduce imports of products linked to deforestation. Producers must also comply with the laws of the producing country. The reversed burden of proof further distinguishes this law.
Reversed burden of proof
The law shifts the burden of proof to the defendant, requiring them to provide evidence that no deforestation occurred after the cut-off date, which must be submitted before shipments are made.
The operators responsible for due diligence
- The obligation and responsibility to submit the required due diligence statement will fall exclusively on the operators who first place the product on the market.
- The first downstream operator in the supply chain will be responsible for collecting and retaining the reference number of the initial due diligence statement, rather than passing it on further down the chain
- Micro and small primary operators will submit only a one-time simplified declaration and will receive a declaration identifier sufficient for traceability.
Commodities covered
The EUDR applies to cattle, cocoa, coffee, oil palm, rubber, soya, wood, and their derivatives or embedded products.
Cut-off date for deforestation
31 December 2020
Penalties
Non-compliance may incur fines of up to 4% of EU turnover. It can also lead to temporary bans from public contracts or funding. Additionally, authorities may confiscate goods.
Your roadmap to compliance: EUDR risk management steps
Understanding and complying with the EUDR requires a meticulous approach. Here's a breakdown of the three-step process:
Information collection
Article 9 outlines the collection of data (e.g., through third-party farm mapping or licensed mapping software), documents, and information that demonstrate product compliance.
This includes detailed descriptions, quantities, country of origin, production site geolocation, supplier information, and proof of deforestation-free sourcing.
Risk assessment
Article 10 requires operators to verify and analyse the information collected. This involves assessing factors such as country risk levels, proximity to forests, the presence of Indigenous peoples, the prevalence of deforestation, and supply chain complexity.
Meridia Verify identifies sustainable sourcing risks across your supply chains. You don’t just identify critical risks; you generate auditable, evidence-based risk assessments that stand up to regulatory scrutiny, with a focus on legality, deforestation, and data quality.
Risk mitigation
Should the risk assessment identify significant risks, operators must take mitigating actions in accordance with Article 10a. This may include providing additional information, conducting independent surveys or audits, or supporting supplier compliance through capacity building and investments.
Verify provides tailored risk-mitigation advice based on the risks identified in the risk assessment conducted in step 2.
Meridia x ICE CoT
A complete EUDR compliance pathway for cocoa and coffee — from data to validated submission.
Verify helps companies prepare for EUDR compliance by supporting due diligence through the identification, assessment, and mitigation of risks across farm-level data, delivering EUDR-ready datasets that can then be used within end-to-end compliance systems such as ICE CoT.
ICE CoT enables the secure and efficient submission, storage, testing, and sharing of due diligence information, facilitating proof of compliance with regulatory requirements and supporting the trade of sustainable cocoa and coffee.
Verify prepares your data. ICE CoT validates, stores, and submits it.
Key questions and answers about EUDR compliance
The EUDR applies to cattle, cocoa, coffee, oil palm, rubber, soya, wood, and their derivatives or embedded products.
The regulation took effect for medium and large companies on 29 June 2023, and will enter into application on 30 December 2026. It applies to all relevant commodities crossing EU borders after the enforcement date, including imports and exports.
For SMEs, compliance becomes mandatory by 30 June 2027.
The cut-off date for deforestation under the EUDR is 31 December 2020.
The law reverses the burden of proof, placing it on the defendant. They need to provide accurate information to the National Competent Authority (NCA) (for example, in the Netherlands, the NVWA). The information must demonstrate that no deforestation occurred after the cut-off date and be verified before the products are shipped.
The EUDR legislation and the published FAQ stipulate the following key aspects for compliance:
- Data quality - “Ensuring the truthfulness and precision of geolocation information is a crucial aspect of the responsibilities that operators and traders must fulfil. Providing incorrect geolocation details would constitute a breach of the obligations under the Regulation.”
Source EUDR FAQ, 02 October 2024
- Deforestation - Clear and reliable information that shows the products do not cause deforestation.
Source EUDR Article 9(1)g
- Legality - Having clear and verifiable information. This shows that the producers made the goods according to the relevant legislation of the country where they produced them.
Source EUDR Article 9(1)h
- Traceability - Traders must collect and keep information. This helps ensure that the supply chain of products is transparent and open.
Source EUDR Article 1 (53)
You must implement a Due Diligence System to demonstrate that you legally source and fully trace your products. Operators and traders follow a structured three-step process:
1. Gather all necessary information.
This includes information about the product's origin. It should show the exact location where it was grown, manufactured, or processed. The EUDR requires the first operators who place a product on the EU market to establish a Due Diligence System to ensure that only goods that comply with the regulation are imported. They must also provide a Due Diligence Statement (DDS) to the relevant NCA. The first downstream operator in the supply chain will be responsible for collecting and retaining the reference number of the initial due diligence statement, rather than passing it on further down the chain.
2. Verify your field data
Use Verify to assess field data quality and conduct a thorough risk assessment of deforestation and legality. Verify assesses factors such as country risk, proximity to forests, Indigenous territories, deforestation, corruption, law enforcement, human rights issues, supply chain complexity, and circumvention risks.
3. Mitigate identified risks.
Verify indicates risks as medium, high, or critical and provides clear, actionable guidance on mitigating them.
4. Submit a DDS
Once all steps are complete, operators and traders must submit a DDS to confirm compliance with EUDR standards.
The EUDR penalties for non-compliance include fines of up to 4% of EU sales. There can also be temporary bans from public contracts and funding. Authorities may confiscate goods as well.
To comply with the EUDR, operators must gather accurate data. This data shows that the products meet the requirements of Article 9.
After finishing the due diligence process, operators must submit a DDS, which includes:
- Description - Trade name, type, and, if applicable, the common and scientific names of wood species used.
- Quantity - Expressed in net mass, volume, or number of units.
- Country of production identification - including specific parts if relevant.
- Geolocation of production plots - with automatic disqualification for any associated deforestation or forest degradation.
- Details of suppliers and recipients of the products.
- Confirmation of deforestation-free status and compliance with relevant production legislation.
Use Meridia Verify to identify and mitigate field-data risks across your supply chains.
Built to meet EUDR standards, Verify ensures compliance with local laws and industry requirements. With Meridia’s decade of field and supply chain expertise, Verify simplifies the process of navigating complex regulations.
Read more about our methodology.
Meridia Verify provides actionable reports to mitigate your field data risks. Mitigation strategies depend on various factors, such as commodity and origin.
A substantiated concern is when individuals or organisations, such as NGOs, formally notify an NCA that an operator or trader may be breaching the regulation’s requirements. The NCA must assess the concern’s credibility and, if justified, initiate an investigation into the suspected non-compliance.
Examples of substantiated concerns include:
- An operator puts goods on the EU market without full chain-of-custody visibility. This is a problem when upstream suppliers break the law. For example, they may produce on Indigenous peoples' land without proper permission.
This mechanism enables stakeholders to monitor and enforce compliance actively, strengthening the regulation’s effectiveness in tackling deforestation.
Together with ICE CoT, Meridia offers a complete EUDR compliance pathway for cocoa and coffee — from data to validated submission.
Meridia Verify helps companies prepare for EUDR compliance by supporting due diligence through the identification, assessment, and mitigation of risks across farm-level data, delivering EUDR-ready datasets that can then be used within end-to-end compliance systems such as ICE CoT.
ICE CoT enables the secure and efficient submission, storage, testing, and sharing of due diligence information, facilitating proof of compliance with regulatory requirements and supporting the trade of sustainable cocoa and coffee.
Verify prepares your data. ICE CoT validates, stores, and submits it