EUDR in practice: A blueprint for deforestation-free supply chains

The EU Regulation on Deforestation-Free Supply Chains (EUDR) is changing the rules of the game for global sourcing. While previous regulations primarily focused on reporting and risk indicators, the EUDR for the first time requires product- and plot-specific proof of deforestation-free production. The goal: to make sustainability more operational – and verifiable.

With the most recent adjustment of the application deadlines, companies are being given more time, but the pressure to act remains: from December 30, 2026, large and medium-sized companies must be fully compliant; from June 30, 2027, micro and small enterprises will also be affected. This means: anyone who only starts in 2027 will be structurally too late.

What does the EUDR require?

At the core of the EUDR are four obligations:

• Deforestation-free production: Production plots must be clearly identifiable (geodata) and must not have been deforested after 31 December 2020.
• Legality: All relevant laws of the country of origin must be complied with and plausibly verified.
• Due diligence: Companies must collect information, assess risks and – where necessary – mitigate them effectively.
• Due diligence statement: A due diligence statement must be submitted before placing products on the market; all data must be retained for at least five years.

The EUDR is therefore less a reporting obligation and more an operational proof requirement that demands robust data, clear processes and traceable decisions along the supply chain.

Who is affected by the EUDR?

A key misunderstanding in the current debate is that the EUDR is often reduced to agricultural operations or raw material producers. In reality, however, this view falls short. The regulation does not address specific industries, but market roles.

What matters is therefore not what a company produces, but which function it performs within the supply chain. The EUDR becomes relevant whenever a company places a covered product on the EU market for the first time, trades it, or is part of complex value chains. This brings importers, traders, processors and brand manufacturers into focus – even if they themselves have no direct link to agricultural production. This role-based understanding is crucial for correctly assessing the requirements and scope of the EUDR.

Data architecture: From documents to robust data

The central challenge in implementing the EUDR rarely lies in a lack of commitment, but almost always in the quality, structure and consistency of existing data. Many companies do have ESG reports, certificates or completed supplier questionnaires, but these information sources are usually stored in unstructured formats. What initially appears to be sufficient documentation proves inadequate for EUDR requirements: the transition from scanned documents and spreadsheets to robust, linkable and auditable datasets that can be processed automatically is missing.

Why traditional approaches are not sufficient

Traditional supply chain management approaches quickly reach their limits under the EUDR. PDF certificates, email attachments or Excel lists:

• cannot be checked automatically,
• cannot be versioned consistently,
• cannot be reliably linked to products, volumes and time periods.

Yet precisely this robustness is a core requirement of the EUDR. Companies must therefore move from document-driven processes to a structured, data-based way of working in order to ensure compliance at all.

Data requirements across supply chain depth

The EUDR only makes sense when it is clear across the entire supply chain who must provide which data and in what context it becomes relevant. Each stage, from the primary producer to the direct supplier, fulfills a specific role. This creates a data flow that enables clear product allocation, traceability of material movements and, ultimately, proof of the required deforestation-free status.

Process blueprint: Translating the EUDR into operational day-to-day business

Implementing the EUDR is far more than a one-off compliance project. It permanently changes how companies manage their supply chains, how they collect data and how they make procurement decisions.

EUDR compliance does not arise within individual departments, but at the interfaces: between procurement, sustainability, compliance, quality management and IT. Only when these areas work seamlessly together can regulatory requirements be consistently integrated into daily operations. A clearly defined process blueprint helps translate complex requirements into manageable steps – from selecting new suppliers and reviewing existing partners to handling risk cases.

1. Onboarding new suppliers: Prevention instead of correction

With new suppliers, the decision is made whether risks are avoided early or corrected later at high cost.

Robust onboarding includes:

• EUDR relevance check of the product
• Collection of structured geodata & legality evidence
• Automated risk classification
• Clear decision: approval, conditions or rejection

→ The key is to establish EUDR criteria as a fixed component of supplier selection, not as a downstream compliance check.

2. Re-onboarding existing suppliers: Acknowledging reality

The biggest challenge almost always lies in the existing supplier base. Long-standing relationships are often built on trust, not on complete data availability.

A pragmatic approach:

• Systematic gap analysis (which data is really missing?)
• Prioritization based on purchasing volume and risk profile
• Structured follow-ups instead of uncoordinated emails
• Temporary transition processes for critical suppliers

→ Important: re-onboarding is change management, not just data collection.

3. Dealing with high-risk suppliers: Clear escalation logic

Not every high-risk supplier must be excluded automatically, but each requires a clear approach.

Typical measures:

• In-depth risk analyses (e.g. satellite data)
• Additional evidence or on-site audits
• Time-limited approvals with milestones
• Clear escalation paths up to supplier replacement

→ What matters is traceability: why was a risk accepted or not?

Practical example: EUDR supplier rating

Let us consider a concrete example of how the abstract requirements of the EUDR can be translated into a robust, operational decision logic:

A European manufacturer sources an EUDR-relevant raw material via several processing stages. The direct supplier (Tier 1) provides complete product and volume data, but the plots of origin lie with several Tier 3 producers in a country with an increased deforestation risk. The key question is: is the risk still negligible, or are additional measures required?

Illustrative EUDR scorecard

At first glance, the country risk appears critical. However, the scorecard shows that this risk is partially offset by good geodata, robust traceability and a high level of operational maturity at the supplier. The aggregated EUDR risk score therefore falls within the medium range.

Derived measures

Based on the identified risk profile, the company does not merely derive individual corrections, but defines a clear action plan covering short-term checks as well as medium- and long-term safeguards. The aim is to address identified risks in a targeted manner without unnecessarily burdening the supplier relationship or prematurely initiating a supplier change.

Typical steps in this example include:
 

Targeted updating of individual polygon data:

The existing geodata is generally usable but shows outdated or imprecise boundary definitions in places. By selectively updating these plots, a more reliable dataset is created, improving the risk analysis and auditability for authorities or auditors.
 

Additional sample-based geodata verification:

To safeguard data quality, the company carries out supplementary spot checks – for example by comparing data with satellite imagery, historical images or independent geospatial data sources. This step is less about correction and more about validation, ensuring that the reported plot information is consistent and plausible.
 

Time-limited approval with monitoring:

As the overall score lies in the medium-risk range and the supplier shows a high willingness to cooperate, approval is granted subject to conditions. This approval is time-limited and accompanied by closer monitoring, including regular status updates, defined milestones and a renewed review after the deadline.
 

The decisive point: a supplier change is not required. Instead, the remaining risk is actively managed, documented and transparently justified. This meets both the EUDR requirements and expectations for an authority-proof, traceable risk assessment – a key aspect in complex supply chains where an immediate change is neither practical nor necessary.

Conclusion: EUDR as a stress test for supply chains

The EUDR is less an environmental requirement than a stress test for data, processes and governance. With the 12-month postponement of the EUDR confirmed on December 17, 2025, more preparation time is available, but regulatory uncertainty also increases: the newly introduced Simplification Review obliges the EU Commission to propose potential changes to the EUDR at the beginning of 2026. It therefore remains unclear which detailed requirements will actually apply from 2026 onwards. Companies must actively monitor this development.

For this very reason, the pressure to act remains high: data architectures, traceability and supplier processes cannot be built overnight. Those who clarify roles, structure data and define operational processes now create a robust foundation – regardless of how technical requirements may further evolve.

From 2026 onwards, Envoria will integrate a full EUDR implementation into its software, enabling companies to centrally manage data, risks and due diligence processes.

In short: the EUDR does not only test supply chains, but organizational capability. And it rewards those who start early despite uncertainty.