The European Deforestation Regulation (EUDR) addresses global deforestation by imposing strict obligations on companies that sell affected products. These obligations require companies to place compliance processes at the core of their operations, ensuring they gather, analyze, and report correct data. As a result, many companies consider it a “mission-critical” regulation that needs to be deeply embedded within their value chain.

EUDR Delayed: What the Extra Time Means for Companies

In November 2024, the respective EU authorities announced a one-year delay in the entry into application of the EUDR, shifting it from December 2024 to December 2025. While some individual companies are as prepared as possible, most value chains remain far from achieving EUDR compliance. This lack was the primary factor behind the EU commission’s proposal to postpone the regulation. 

Achieving full EUDR compliance requires companies to establish processes and systems that can operate seamlessly within the daily business activities. However, implementing compliance systems comes with a set of organizational tasks—particularly around supplier and customer engagement. Experience suggests that these organizational tasks can take several months to complete. 

Given the additional time provided by the delay, it is recommended for companies to focus on two key areas: 

1. Addressing organizational tasks to clear any obstacles early. 
2. Defining target processes and setting up systems to ensure they can run effectively. 

What Companies Need for EUDR Compliance

The basic requirements—data gathering, due diligence, and reporting—are well documented. However, the steps companies should take to achieve full EUDR compliance are less clear. The following paragraphs will aim at giving some concrete guidance. 

To begin with, there are organizational activities companies should prioritize when preparing for EUDR. While not exhaustive, these typically include: 

• Understanding EUDR impact: Identifying which products and supply chains are affected by the regulation. 
• Defining relevant scenarios: Determining the various roles in which the company acts as an EUDR-relevant entity, such as import activities, production processes, or trading. Each scenario carries specific implications for the necessary processes and compliance steps. 
• Assessing current operations: Gaining a deep understanding of existing operations and associated (IT) processes for each scenario. Although this may seem straightforward, a detailed grasp of these mechanics is essential for enabling efficient and smart automation. 
• ERP preparation: Larger companies aiming for comprehensive IT integrations should leverage insights from the previous steps to streamline ERP systems. This includes cleaning up master data and adding key fields, such as HS codes for products. While seemingly mundane, these steps can significantly ease compliance efforts later. 
• Engaging with suppliers: Building the necessary communication channels to support data collection and compliance efforts.  

All of these activities can be completed without specialized software but are highly advisable to ensure smooth and efficient EUDR implementation and compliance. 

When it comes to ongoing activities within daily operations, generalizations are difficult but typically include: 

• Gathering supplier data: Primarily geolocation data or due diligence statement (DDS) data, depending on the case. Ideally, data should be collected with every purchase to enable effective risk management. 
• Performing due diligence: Ensuring compliance for every incoming shipment before accepting physical goods. This step helps confirm that only compliant products are bought, processed, and sold. 
• Creating and submitting DDS: Generating due diligence statements and submitting them to the relevant EU interface (e.g., TRACES) whenever required. For example, coffee roasters would submit a DDS whenever roasting or selling roasted coffee. 
• Sharing information with customers: Providing all relevant compliance data to downstream customers, such as retailers. 

By systematically addressing these organizational and operational activities, companies can lay a strong foundation for achieving and maintaining EUDR compliance.

Short-Term Priorities: Levers to Pull Now

Organizational tasks that do not require specialized software should be addressed immediately to make tangible progress toward EUDR compliance. Key focus areas include: 

• Scenario analysis: Identifying how the company is impacted by EUDR across various roles (importer, producer, trader) and determining the specific requirements for each scenario. 
• Supply chain engagement: Initiating communication with suppliers to collect necessary data and align on EUDR requirements. 
• Engaging key stakeholders: Bringing internal teams (procurement, IT, compliance) and external partners up to speed to ensure alignment on goals and responsibilities. 

The Target State: Seamless Compliance as Part of Core Operations

When companies discuss their ideal operating model for EUDR, the goal is clear: compliance should seamlessly integrate into core operations, requiring minimal additional effort. Contributing meaningfully to stopping deforestation should not feel like a burden, but rather a natural part of business processes—affecting suppliers and customers as little as possible. 

Achieving this target state requires well-designed systems and compliance processes that integrate effectively with existing business workflows. Software solutions for EUDR compliance should leverage existing IT infrastructure to operate autonomously.

Example: A Target Model for Coffee Roasters

To illustrate, let’s consider the target model for a coffee roaster: 

1. Automated data requests: Contract data synchronized from the roaster’s ERP system triggers automatic data requests to suppliers. 
2. Data collection: Due diligence statements (DDS) or geolocation data are automatically transmitted, either through APIs connected to supplier systems or because the suppliers themselves use osapiens.. Manual intervention is only needed if suppliers fail to respond to requests and reminders. 
3. Automatic risk analysis: The system analyzes deforestation, legality, and supply chain risks based on the received data. 
4. High-risk findings: If high risks are detected and cannot be mitigated with existing information, an automatic case is created. A dedicated employee investigates, documents, and evaluates all measures in an audit-proof manner. 
5. DDS creation for imports: Once the contract is deemed negligible risk, the system automatically generates a DDS, pulling all required data to facilitate submission to TRACES NT through an existing API. 
6. Batch traceability and production: When shipments are received and roasted, batch traceability data is sent from the ERP system to the compliance software. This triggers automatic DDS generation for roasted coffee, including all relevant data for EUDR. 
7. Data sharing: Once DDS numbers and validation tokens are obtained, they can be reused in the roaster’s ERP system for easy access and sharing with customers (e.g., retailers via EDI) or provided through a dedicated portal. 

Key Takeaways: Example: A Target Model for Coffee Roasters

For a coffee roaster—or any other company affected by EUDR —a software solution should focus on automating highly repetitive processes such as data collection, analysis, and reporting. These tasks, when done manually, are not only labor-intensive but also prone to errors. Integrating them into existing ERP systems and workflows enables a smooth, automated process for EUDR compliance. 

To summarize, companies are strongly advised to: 

• Start tackling organizational preparations immediately. 
• Begin defining their target operating model to ensure they are ready to run EUDR-compliant processes efficiently by the time the regulation takes effect. 
• Find software that can automate these EUDR processes.