EUDR FAQ: First Operators, Due Diligence, and Practical Implementation

Following our recent webinars on the EU Deforestation Regulation (EUDR), we received a high volume of concrete, practice-oriented questions from companies across industries preparing for EUDR compliance. This FAQ addresses the most common of these questions, with a focus on First Operators, Due Diligence Statements (DDS), data exchange, and real-world implementation challenges.

1. How are we able to know if our suppliers are first operators? Do we have to ask all of them for their position in the supply chain?

First Operators are those who first place a commodity on the EU market and therefore must perform full due diligence and issue the Due Diligence Statement (DDS), while downstream operators rely on DDS numbers received from upstream.
In practice, companies need to clarify their own and their suppliers’ roles, especially in complex or multi-tier supply chains. You can only determine whether a supplier is a First Operator by directly communicating with them, because EUDR provides no public registry for supplier roles.

To classify your suppliers, you must determine:

• If they import or first place the product on the EU market, and
• if they issue a DDS in TRACES.

Software-supported supplier data verification and validation can make these checks faster and less error-prone.

2. How can osapiens support companies with DDS reference sharing and EUDR traceability?

osapiens supports companies in securely sharing correct DDS reference numbers and meeting EUDR traceability obligations by:

• Automated DDS submission: streamlined due diligence workflows and filing DDS directly into TRACES, ensuring accurate reference numbers are generated and available for downstream partners.
• Data‑driven aggregation: automated consolidation of product, sales batch, intermediary goods, and transfer data, streamlining product aggregation and ensuring consistent traceability across complex supply chains.
• Seamless downstream data sharing: through multiple options like a free of charge customer portal or the osapiens Data Network. Automatically deliver validated DDS information to the first downstream operator.

Together, these features ensure DDS references are shared efficiently and correctly, and that EUDR traceability requirements are consistently fulfilled across the supply chain.

3. When will the next official EUDR FAQs be published?

There has been no official communication yet. We expect that updated FAQs will be published towards the end of Q1 / beginning of Q2 2026.

4. What if I am sourcing from a small or micro enterprise with delayed EUDR entry (mid 2027)?

If your supplier is a small or micro enterprise, this means they are not required to perform EUDR due diligence until 30 June 2027.
As a result, larger downstream operators do not have to conduct EUDR due diligence, provided the product was placed on the EU market before the respective date of application.
However, downstream operators must still collect and be able to verifiably document that these products were imported or placed on the EU market prior to 30 June 2027.

5. How can I share EUDR data with customers who don’t use the osapiens platform?

If a customer chooses not to use the osapiens platform, EUDR-relevant data can be shared using alternative methods:

• Existing communication channels: Extract the information from the osapiens HUB and share it through the channels you already have in place with your customer.
• Data exports: Provide EUDR data in various file formats that your customer can receive without using the platform.

This allows companies to meet downstream information obligations even when customers do not want to use the free customer portal. However, using the portal helps automate EUDR processes and reduce manual errors along the supply chain, making compliance easier and more efficient.

6. How does osapiens keep its software up to date with EUDR changes?

osapiens works closely with legal experts to ensure that the software evolves with regulatory developments. This continuous alignment ensures that companies remain compliant with future regulatory changes.

7. How do we prove that no deforestation happened after the cut-off date in 2020?

The osapiens HUB for EUDR uses a comprehensive approach to assess deforestation and forest degradation risks.

First, the system validates and optimizes uploaded geodata to ensure it meets technical requirements. Next, it identifies whether forests were present on the provided land plots as of the critical cut-off date of December 31, 2020. Finally, the system analyzes multiple satellite imagery to detect any potential deforestation or forest degradation activities.

This systematic approach ensures reliable, accurate assessments that comply with EUDR requirements.

8. What practical challenges do companies face when implementing EUDR and how can osapiens help?

Common challenges First Operators face include:

• Collecting reliable data across global supply chains efficiently
• Performing compliant deforestation and legal risk assessments at scale
• Preparing relevant data for DDS submission and downstream data sharing
• Reducing manual steps that are time-consuming, risky, and costly

osapiens helps companies overcome these challenges with:

• Integrated data collection options, available in over 25 languages globally
• Embedded EUDR-specific risk assessments which ensure EUDR compliance
• Automated DDS submission to TRACES and seamless data sharing downstream
• Fully automatable end-to-end workflows, including out-of-the-box settings for quick setup

9. How can osapiens help onboard global suppliers quickly and efficiently?

osapiens makes onboarding global suppliers fast and seamless with embedded workflows that guide users step by step. An integrated help center provides instant access to key instructions while interactive guides and videos offer clear, visual explanations of features.

To support deeper learning, we also host regular webinars with live Q&A sessions. Out-of-the-box questionnaires also help tailor the onboarding experience to each supplier’s needs.

Dive deeper

If you’d like to explore these topics in more detail, we invite you to register for our webinar series on EUDR:

• EUDR for First Operators – a practical webinar series for importers: dedicated to importers, focusing on the EUDR Process for first operators, including deep dives into the software features.
• EUDR Readiness 2026 – a living webinar series that takes place every month and provides you with the latest EUDR updates and practical guidance.

Both webinar series provide deep insights, real-world EUDR scenarios, and live demonstrations of how companies can operationalize EUDR compliance at scale.