EUDR: deforestation-free supply chains

In brief

The EU Deforestation Regulation, EUDR for short, covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soy and wood. It also covers many products made from them, listed in Annex I, such as leather, chocolate, furniture, paper or soybean meal. These goods may only be placed on the EU market or exported from it if three conditions are met (Art. 3):

• They are deforestation-free, meaning the land was not deforested after December 31, 2020 (Art. 2(13)).
• They were produced legally under the law of the country of production, for example in terms of land rights, environmental law, labor law and tax law.
• A due diligence statement for them has been filed in the EU information system.

The due diligence statement is filed by the EU operator, which is usually the importer. To do so, the operator must collect information (Art. 9), assess the risk (Art. 10) and mitigate it where necessary (Art. 11). The core of the information is the geolocation of every plot of land on which the goods were produced (Art. 9(1)(d)). For plots larger than four hectares, a polygon is required instead of a single point, except for cattle.

The regulation has been amended twice: by Regulation (EU) 2024/3234, which pushed the start date back by a year, and by Regulation (EU) 2025/2650, which postponed it again and introduced simplifications, among them fewer reporting obligations for downstream companies and traders.

Who it affects in South America

The legal obligation sits with the operator in the EU. In practice, every producer and exporter whose goods go there is affected, because without geolocation data and proof of legality the buyer cannot file a due diligence statement and cannot sell the goods.

The Commission classifies countries by risk (Art. 29, Implementing Regulation (EU) 2025/1093). Chile and Uruguay are rated low risk. Argentina, Bolivia, Brazil, Colombia, Ecuador, Paraguay and Peru are standard risk. No country in South America is rated high risk.

How much work you face depends heavily on your supply chain. A large farm in Mato Grosso that works its own land knows its polygons. A coffee exporter in Huila that buys from hundreds of smallholders through intermediaries first has to map every single plot. With cattle the chain is often long, because animals pass through several farms before slaughter. The regulation requires the geolocation of every establishment where the animals were kept.

Deadlines

On May 4, 2026, the Commission presented its simplification report and did not propose any further postponement. Plan on December 30, 2026. A harvest of coffee from Huila or soy from Paraná that arrives in Hamburg or Rotterdam in the first half of 2027 needs the data today.

Member states enforce the rules. Article 25 provides, among other things, for fines with a maximum of at least 4% of the company's annual turnover in the EU, as well as confiscation of the goods and the revenue from them, and temporary exclusion from public contracts. Your buyer bears these risks, and it will pass them on to you in its contracts, for example through warranties and withdrawal rights.

What EU customers actually ask for

• Geographic coordinates of every production plot, as a polygon for plots larger than four hectares.
• Harvest period or production date, quantity and tariff code (HS code).
• Names and addresses of the suppliers in the chain back to the producer.
• Proof of legality: land titles, environmental permits, in Brazil for example registration in the CAR environmental registry, and evidence of compliance with labor and tax law.
• A check against the cut-off date, usually based on satellite imagery.
• Evidence that product flows are kept separate, so verified goods are not mixed with unverified ones.
• For resale, the reference number of a due diligence statement that has already been filed.

Certifications such as RTRS or ProTerra for soy, FSC or PEFC for wood, Rainforest Alliance for coffee and cocoa or RSPO for palm oil help with data collection. They do not replace the due diligence obligation, though, and the EU buyer will still ask for the geolocation data.

First steps

1. Use the customs tariff to check for each product whether it falls under Annex I.
2. Map the plots of every producer you buy from. With cooperatives that have many smallholders, this is the biggest effort, so start early.
3. Check the plots against the December 31, 2020 cut-off date. Public satellite data and specialized services can help.
4. Collect proof of legality for each producer and keep it up to date.
5. Set up your logistics so that verified goods stay separate.
6. Agree with your EU buyers on the format in which they need the data.

Decide who in the company is responsible for the data. Buyers ask at short notice, often for individual containers, and a supplier that can answer within hours stays the supplier of choice. Land titles, permits and supplier declarations each have an expiry date. A GRC tool such as Sightadel can hold them as evidence per supplier, assign renewal tasks and keep the supplier assessment in one place. The geolocation and satellite checks themselves need a specialized service.

The free EU Readiness Check gives you an assessment of where you stand.

How it relates to certifications

The EUDR does not require a certificate. Environmental management under ISO 14001 does show that you manage environmental risks systematically, and it makes the documentation easier. For food exporters, the food safety standards such as IFS, BRCGS or FSSC 22000 remain in place alongside it, because food retailers require them regardless of the EUDR. Many of your buyers' questions overlap with the due diligence obligations under the CSDDD and CSRD and, from December 14, 2027, with the Forced Labour Regulation, which also requires traceability back to the producer. If you map your supply chain properly once, you can use the data for all three. That saves collecting the same data twice from the same producers.

The EU-Mercosur Agreement does not change anything about the EUDR. Tariff advantages only apply to goods that also meet the EU's product rules.

FAQ