Do third-party audits play a role in EUDR compliance?

Do third-party audits play a role in EUDR compliance?

Third-party audits can be useful tools to verify supply-chain data and strengthen confidence in compliance, but they are not a substitute for the mandatory due diligence process. Certifications or audit reports alone do not exempt companies from EUDR obligations — businesses must still submit a Due Diligence Statement (DDS) with geolocation data and evidence of deforestation-free sourcing.

Are there any exemptions to the EUDR?

Are there any exemptions to the EUDR?

The EUDR does not provide exemptions based on certification schemes. While certifications such as FSC (Forest Stewardship Council) or RSPO (Roundtable on Sustainable Palm Oil) can support supply-chain transparency and help demonstrate compliance, they do not replace the mandatory due diligence requirements.

 All operators and traders must submit a Due Diligence Statement (DDS) and provide evidence that products are deforestation-free and legally produced, regardless of certification status.

Traceability, Geolocation & Risk Assessment

How does the EUDR affect businesses importing commodities?

Importers, referred to under the regulation as operators or traders, must conduct thorough due diligence across their supply chains. This involves collecting required data, verifying compliance with legality and deforestation-free status, and obtaining plot-level geolocation data for production sites. They must then prepare and submit a valid Due Diligence Statement (DDS) through the official EU Information System to demonstrate compliance.

Do I need to conduct risk assessments for EUDR compliance?

Yes, businesses must assess the risk of deforestation and forest degradation within their supply chains to ensure products are sustainably sourced.

How do I manage risk assessments across multiple product batches?

Risk assessments must be performed for each batch, with robust traceability systems to manage and document assessments.

What role does geospatial data play in EUDR compliance?

Under the EUDR, geolocation data (plot-level coordinates) is a mandatory element of due diligence. Companies must provide precise geospatial information for the production plots where commodities originate to demonstrate that products are deforestation-free and legally produced. 

While certifications (e.g., FSC, RSPO) can support supply-chain transparency, they cannot replace geolocation data or the mandatory Due Diligence Statement (DDS). Geospatial data is essential for authorities to verify sourcing and ensure compliance.

Due Diligence Statement (DDS) & Documentation

What is a Due Diligence Statement (DDS) under the EUDR?

A Due Diligence Statement (DDS) is a mandatory declaration confirming that a product or batch placed on or exported from the EU market does not contribute to deforestation or forest degradation.

The DDS must include:

  • Geolocation data of the production plots
  • Supplier and buyer details
  • Quantity and country of production
  • Evidence of compliance with local laws
  • Assurance of deforestation-free status

Companies are required to retain all due diligence documentation for at least five years to demonstrate ongoing compliance.

What information is required in a Due Diligence Statement (DDS)?

The DDS should include product origin, sustainability certifications, environmental risk assessments, and evidence of deforestation-free sourcing.

How do businesses demonstrate EUDR compliance?

Through traceability, risk assessments, and submitting Due Diligence Statements (DDS) for each product batch imported into the EU.

Is the submission of the DDS a one-time requirement or batch-by-batch?

Under the updated 2025 guidance, submission of a Due Diligence Statement (DDS) is no longer strictly required for every single batch.

For certain operators, it may be possible to reuse DDS when reimporting goods or to submit DDS less frequently than per batch. These simplifications are still evolving, and companies should follow the latest EU guidance to confirm how the changes apply to their operations.

General Overview & Scope

What is the EU Deforestation Regulation (EUDR)?

The EU Deforestation Regulation (Regulation (EU) 2023/1115), adopted in May 2023, aims to ensure that products placed on the EU market or exported from it do not contribute to deforestation or forest degradation. It requires that commodities such as palm oil, cocoa, soy, coffee, and timber, among others, originate from land that has not been deforested or degraded after December 31, 2020, and that they are produced in a legally compliant manner.

Which products are covered under the EUDR?

The EUDR applies to commodities such as cocoa, coffee, palm oil, soy, timber, rubber, and cattle (including beef and other cattle-derived products), along with their derivatives like chocolate, furniture, and paper-based packaging.

How do I determine if my product needs to comply with the EUDR?

Your product must comply if it contains any of the regulated commodities — cattle (beef), cocoa, coffee, palm oil, soy, timber, or rubber. 

Not all derived products are automatically covered. Only those specifically listed under Annex I (HS codes) fall within scope, such as chocolate, wooden furniture, palm oil derivatives used in food and cosmetics, etc.

What is the timeline for EUDR compliance?

The EU Deforestation Regulation (EUDR) was adopted in May 2023.

As per the 2025 update, the compliance deadlines are:

  • Large and medium-sized companies must comply by 30 December 2026.
  • Small and micro-enterprises must comply by 30 June 2027.

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