Chapter 7 / 7
Preparation strategy (December 2026)
Action plan for EUDR compliance before December 2026: supply chain audit, certification, traceability systems and risk mapping.
Related tool: - Try the tool →Preparation roadmap
EUDR compliance is not a single project -- it is a systemic transformation of supply chain management practices. This chapter provides a structured action plan for operators and traders at different stages of readiness, organised into short-term (immediate), medium-term (6-12 months), and long-term (12-24 months) horizons.
The approach follows a clear hierarchy: map first, assess second, build systems third, then optimise.
Short-term actions (immediate -- next 3 months)
1. Product scope assessment
Objective: determine exactly which products in your portfolio are covered by the EUDR.
- Compile a complete list of products you import, produce, export, or trade
- Identify the CN code for each product using the TARIC nomenclature or the automated classification tool
- Cross-reference each CN code against Annex I of Regulation 1115/2023
- Flag composite products that may contain covered commodities (leather goods, chocolate, paper products, rubber articles)
- Document the volume and value of in-scope products for risk prioritisation
2. Supply chain mapping
Objective: identify all actors, processing stages, and countries of origin in your supply chains.
| Supply chain element | Data to collect | Priority |
|---|---|---|
| Tier 1 suppliers | Name, location, products supplied, volumes | Critical |
| Tier 2+ suppliers (upstream) | Name, country, commodity sourced | High |
| Processing facilities | Location, blending/segregation practices | High |
| Country/region of production | Specific region (sub-national) | Critical |
| Logistics chain | Ports, warehousing, transport modes | Medium |
For each supply chain, identify the critical control points where traceability may be lost (blending at mills, aggregation at warehouses, transshipment at ports).
3. Supplier engagement
Objective: communicate EUDR requirements to suppliers and assess their readiness.
- Send formal notifications to all suppliers of in-scope commodities explaining the EUDR's requirements
- Request a self-assessment of their current traceability capabilities (geolocation data, plot-level records, satellite monitoring)
- Identify suppliers who can already provide the required data vs. those who need support
- Prioritise engagement with high-risk suppliers (those sourcing from regions with high deforestation rates)
- Include EUDR compliance clauses in contract renewals and new agreements
4. Regulatory registration
Objective: ensure you can access the EUDR information system and submit due diligence statements.
- Verify your EORI number is active and up to date
- Register for access to the EUDR information system (when available)
- Designate a responsible person within your organisation for EUDR compliance
- If acting as an authorised representative for non-EU operators, formalise the mandates in writing
- Brief your customs broker on the EUDR reference number requirement
Medium-term actions (6-12 months)
5. Geolocation data collection
Objective: build the geolocation dataset required for due diligence statements.
- Work with suppliers to collect GPS coordinates for all production plots
- For plots over 4 hectares: obtain polygon coordinates delineating the perimeter
- For plots of 4 hectares or less: obtain single-point coordinates (latitude/longitude)
- Validate coordinates against satellite imagery to confirm accuracy
- Store geolocation data in a structured, queryable database
- See chapter 4 for technical specifications
Estimated effort by commodity:
| Commodity | Typical supply chain depth | Geolocation difficulty | Estimated cost per supplier |
|---|---|---|---|
| Wood (plantation) | 2-3 tiers | Medium (concession-level data often exists) | EUR 500-2,000 |
| Palm oil | 3-5 tiers | High (smallholders, mill aggregation) | EUR 2,000-10,000 |
| Soy | 2-3 tiers | Medium (large farms, satellite-identifiable) | EUR 500-3,000 |
| Cocoa | 3-5 tiers | Very high (millions of smallholders, 2-3 ha avg) | EUR 5,000-20,000 |
| Coffee | 3-5 tiers | High (smallholders, cooperative aggregation) | EUR 3,000-15,000 |
| Cattle | 3-6 tiers | Very high (animal movement, indirect suppliers) | EUR 5,000-25,000 |
| Rubber | 3-5 tiers | High (smallholders in remote areas) | EUR 3,000-15,000 |
6. Risk assessment framework
Objective: establish a systematic methodology for assessing deforestation risk.
- Develop a risk assessment matrix combining country risk, supply chain risk, and product-specific risk (see chapter 3)
- Integrate available data sources: Global Forest Watch, country benchmarking (when published), NGO reports, government databases
- Define internal risk thresholds: what level of risk triggers enhanced verification vs. supplier replacement
- Assign risk scores to each supply chain and prioritise mitigation efforts accordingly
- Document the methodology for audit purposes
7. Due diligence system design
Objective: build the procedural and technical infrastructure for ongoing compliance.
Process design:
- Define the due diligence workflow (information collection, risk assessment, risk mitigation, statement submission)
- Assign roles and responsibilities (compliance team, procurement, logistics, legal)
- Establish escalation procedures for non-negligible risk findings
- Design internal audit and review cycles (at minimum annual, per Article 12)
Technical infrastructure:
- Select or build a traceability platform that can store geolocation data, supplier records, and risk assessments
- Integrate satellite monitoring capabilities (Global Forest Watch API, commercial providers)
- Connect the traceability platform with your ERP and customs declaration systems
- Ensure the system can generate the data required for due diligence statements
8. Pilot testing
Objective: test the due diligence system on a representative sample before full rollout.
- Select 2-3 supply chains covering different commodities and risk levels
- Run the complete three-step process: information collection, risk assessment, risk mitigation
- Submit test due diligence statements (when the information system is available)
- Identify gaps, bottlenecks, and areas for improvement
- Refine the system based on lessons learned
Long-term actions (12-24 months)
9. Continuous monitoring
Objective: establish ongoing surveillance of sourcing areas and supply chains.
- Set up automated satellite monitoring alerts for all production plots in your portfolio
- Implement periodic re-assessment of supplier risk profiles (quarterly or semi-annually)
- Monitor country benchmarking updates from the Commission
- Track developments in producing countries (legislation changes, enforcement actions, deforestation trends)
- Maintain a "watch list" of high-risk supply chains requiring enhanced attention
10. Supply chain restructuring
Objective: adapt supply chains to reduce risk and improve compliance efficiency.
- Consolidate suppliers: reduce the number of suppliers to those with demonstrated compliance capacity
- Shorten supply chains: direct sourcing reduces traceability complexity
- Diversify origins: reduce dependence on high-risk regions
- Invest in supplier capacity: support smallholders and cooperatives in building traceability infrastructure
- Join industry initiatives: pre-competitive collaboration on shared challenges (see certification section below)
11. Organisational capability building
Objective: embed EUDR compliance into organisational culture and processes.
- Train procurement, logistics, and compliance teams on EUDR requirements
- Integrate EUDR due diligence into existing compliance management systems
- Establish KPIs for EUDR compliance (percentage of supply chains mapped, geolocation coverage, risk assessment completeness)
- Conduct internal audits of the due diligence system
- Report EUDR compliance metrics to management
The role of certification schemes
Certification schemes can support but do not replace EUDR due diligence (see chapter 3). Here is how key schemes align with EUDR requirements:
| Scheme | Commodities | Geolocation | Deforestation cut-off | Legality | EUDR alignment |
|---|---|---|---|---|---|
| FSC (Forest Stewardship Council) | Wood | Concession-level | Varies (1994 baseline) | Yes | Partial -- cut-off mismatch |
| PEFC | Wood | Varies | Varies | Yes | Partial |
| RSPO (Roundtable on Sustainable Palm Oil) | Palm oil | Mill-level (RSPO Next: plot-level) | Nov 2005 | Yes | Partial -- cut-off mismatch, but RSPO Next closer |
| Rainforest Alliance | Cocoa, coffee, tea | Farm-level mapping | Jan 2014 | Yes | Closer -- geolocation improving |
| UTZ (now Rainforest Alliance) | Cocoa, coffee | Farm-level | 2008 | Yes | Merged into RA |
| Fairtrade | Coffee, cocoa | Cooperative-level | None specific | Yes | Limited geolocation |
| ProTerra | Soy | Farm-level | 2004 (Cerrado) / 2008 | Yes | Partial |
| ISCC (International Sustainability & Carbon Certification) | Palm oil, soy | Plot-level | Various | Yes | Strong alignment |
Key insight: no single certification scheme currently meets all EUDR requirements. The most common gaps are:
- Cut-off date mismatch: most schemes use earlier baselines, not the EUDR's 31 December 2020
- Geolocation granularity: many schemes operate at concession or cooperative level, not individual plot level
- Scope: schemes may cover deforestation but not all legality requirements of the country of production
Operators should treat certification as one input into their risk assessment, not as proof of compliance.
Cost estimation
Direct compliance costs
| Cost category | One-time | Recurring (annual) | Notes |
|---|---|---|---|
| Product scope assessment and supply chain mapping | EUR 10,000-50,000 | EUR 5,000-20,000 | Depends on portfolio complexity |
| Geolocation data collection | EUR 20,000-200,000 | EUR 10,000-50,000 | Heavily dependent on commodity and supplier count |
| Traceability platform (SaaS) | EUR 5,000-20,000 setup | EUR 12,000-60,000/year | Commercial platforms vary widely |
| Satellite monitoring subscription | -- | EUR 5,000-30,000/year | Free tools available but limited |
| Risk assessment and due diligence | EUR 10,000-30,000 | EUR 20,000-80,000/year | Staff time + external expertise |
| Staff training | EUR 5,000-15,000 | EUR 3,000-10,000/year | Initial + refresher |
| External legal and compliance advice | EUR 10,000-50,000 | EUR 5,000-25,000/year | Regulatory interpretation, contracts |
Total estimated cost for a mid-size importer (EUR 50-200M turnover, 5-15 covered supply chains): EUR 80,000-250,000 in Year 1, declining to EUR 50,000-150,000/year from Year 2 onwards.
Cost mitigation strategies
- Collaborate with competitors on shared supply chains (pre-competitive data sharing)
- Leverage existing certifications as a starting point (do not rebuild from scratch)
- Use free satellite monitoring tools (Global Forest Watch, Copernicus) before investing in commercial solutions
- Negotiate cost-sharing with suppliers (the producing country also benefits from market access)
- Integrate EUDR with other due diligence (CSDDD, forced labour) to avoid duplication
Regulatory synergies
The EUDR does not exist in isolation. Smart compliance strategies address multiple regulations simultaneously:
EUDR + CSDDD (Corporate Sustainability Due Diligence Directive)
- Overlap: both require supply chain due diligence on environmental impacts
- Synergy: the EUDR's plot-level traceability satisfies much of the CSDDD's environmental due diligence requirement for relevant commodities
- Efficiency: build one integrated due diligence system covering both regulations
EUDR + Forced Labour Regulation (2024/3015)
- Overlap: supply chain traceability, country-of-origin documentation, risk-based approach
- Synergy: EUDR geolocation data helps identify high-risk regions for forced labour (e.g., rubber in Myanmar, cocoa in West Africa)
- Efficiency: supplier assessments can cover both deforestation risk and forced labour indicators
EUDR + CBAM
- Limited overlap: different product scope (CBAM covers industrial goods, EUDR covers agricultural commodities)
- Synergy: both require accurate CN code classification and customs interface -- invest in classification infrastructure once
- Tools: use automated classification and nomenclature lookup to determine coverage under both regulations simultaneously
EUDR + CSRD (Corporate Sustainability Reporting Directive)
- Overlap: deforestation disclosure, supply chain transparency, environmental metrics
- Synergy: EUDR due diligence data feeds directly into CSRD reporting on deforestation-related impacts
- Efficiency: structure EUDR data collection to be CSRD-reporting-ready from the start
Key success factors
Based on early implementation experience, the following factors distinguish well-prepared operators from those struggling with compliance:
- Start upstream: begin with suppliers, not with your own systems. Without supplier data, no amount of internal process will suffice.
- Prioritise by risk: focus first on high-risk, high-volume supply chains. Do not try to solve everything simultaneously.
- Invest in relationships: EUDR compliance depends on trust and cooperation with suppliers. Coercive approaches backfire.
- Build for scale: choose systems and processes that can handle growth in scope (new commodities, new suppliers, new regulations).
- Document everything: the due diligence system must be demonstrable to competent authorities. If it is not documented, it does not exist.
- Stay informed: the regulatory landscape is evolving. Monitor Commission guidance, benchmarking publications, and enforcement precedents.
EUDR preparation strategy checklist
Frequently Asked Questions
- How much will EUDR compliance cost my company?
- Costs vary enormously depending on the number and complexity of supply chains, the commodities involved, and existing traceability infrastructure. For a mid-size importer (EUR 50-200M turnover, 5-15 covered supply chains), expect EUR 80,000-250,000 in Year 1 and EUR 50,000-150,000/year thereafter. The largest cost drivers are geolocation data collection (especially for smallholder commodities like cocoa and coffee) and traceability platform subscriptions.
- Should I wait for the country benchmarking before starting preparation?
- No. The regulation is already applicable for large operators (since 30 December 2025). All countries are currently treated as standard risk (9% control rate). Waiting for the benchmarking means losing preparation time. Start with supply chain mapping, supplier engagement, and geolocation data collection -- these are required regardless of the country risk classification.
- Can I use the same due diligence system for EUDR and CSDDD?
- Yes, and this is strongly recommended. Both regulations require supply chain due diligence on environmental impacts. Building an integrated system that covers deforestation (EUDR), broader environmental impacts (CSDDD), and potentially forced labour (Regulation 2024/3015) is more cost-effective than maintaining separate compliance silos. The EUDR's plot-level traceability data satisfies much of the CSDDD's environmental due diligence requirement for relevant commodities.
- What if my supplier refuses to provide geolocation data?
- Without geolocation data, you cannot submit a valid due diligence statement and therefore cannot legally place the product on the EU market. You have three options: (1) work with the supplier to build traceability capacity (the preferred approach), (2) find an alternative supplier who can provide the required data, or (3) discontinue sourcing from that supplier. In practice, market pressure from multiple EU buyers is driving rapid adoption of geolocation reporting by major producing-country suppliers.
- Are there industry initiatives that can help reduce the burden?
- Yes. Several pre-competitive industry initiatives are addressing shared EUDR challenges: the Cocoa & Forests Initiative, the Global Coffee Platform, the Consumer Goods Forum Forest Positive Coalition, the European Sustainable Palm Oil initiative, and the Accountability Framework initiative. These platforms facilitate shared data infrastructure, common risk assessment methodologies, and collective supplier engagement. Joining relevant initiatives is one of the most cost-effective ways to accelerate compliance.