On April 16, 2025, the EU released FAQ Version 4 for the EU Deforestation Regulation (EUDR). This document clearly establishes the rules for placing certain commodities and products on the EU market and for their export. As this regulation comes into application, one of the core requirements for operators and non-SME traders is robust supply chain traceability. To ensure your products meet EUDR standards, it is crucial to understand these traceability obligations and implement effective systems. 

In this blog we have compiled all relevant updates and additions to the EUDR FAQ Version 4. From ensuring robust traceability to dealing with changes in scope and definitions, we will guide you through all the revisions in one of the most detailed EUDR FAQs to date. 

Here’s How the EUDR FAQ (Version 4) Addresses Supply Chain Traceability 

One of the core components of the EUDR is traceability to the plot of land where the commodities were produced. This involves collecting and documenting information about the journey of your products, including the geolocation data starting from their origin. The new FAQ also emphasizes the use of remotely sensed information, such as aerial or satellite images, to verify the geolocation of the declared commodity and its link to deforestation. 

To fulfill these traceability requirements, operators (and non-SME traders who are placing or exporting products not already covered by a compliant DDS from an upstream operator) need to collect and keep specific information for five years to demonstrate compliance. This includes: 

• The commodity or product they intend to place on the EU market or export. 

• The quantity of the product, details of the supplier, and the country of production. 

• Evidence of legal harvest, and the date and time range of production. 

• The geographic data of the plots of land where the relevant commodity was produced. 

This information must be submitted in a Due Diligence Statement (DDS) via the Information System prior to placing the products on the EU market or exporting them. Without a valid DDS, such market actions are prohibited. 

What’s New for Traceability in EUDR FAQ Version 4: Key Changes in Focus 

Bulk-Traded and Composite Products 

For bulk products like soy or palm oil, it is crucial to ensure that all plots of land involved in the shipment are identified. Since these commodities are traded in bulk, these shipments must not be mixed with commodities of unknown origin, or from deforested and/or degraded areas after the cut-off date (Dec. 31, 2020). 

For composite products like furniture, operators are obligated to include the geolocation of all plots of land (or reference a previous DDS that contains the geolocation of the land plot) where the relevant commodity (in this case: wood) used in manufacturing was produced.  

When referencing a previous DDS from an upstream supplier, it is important to note that downstream operators and traders remain fully liable for compliance. Annual reviews and risk checks on suppliers are recommended to meet this responsibility.

Defining the Date or Time Range of Production 

Under the EUDR, operators are required to collect the date and time range information for all relevant commodities. However, it is important to note that these information requirements are defined differently based on the nature of the product. 

For all the relevant commodities other than cattle, the date of production refers to the date of harvest, and the time range refers to the duration of the production process. For cattle, however, the time range takes into account the entire lifetime of the animal: from birth to slaughter. 

For live cattle, operators must collect and submit all geolocation data up to the first placement on the EU market as part of the DDS. If the cattle are sold further along the supply chain, non-SME traders must add geolocations of any additional establishments where the animals were kept after the initial placement. 

Fulfilling Obligations for Livestock Feed 

The new FAQ version clarifies that geolocation of livestock feed is not required unless the feed is a listed EUDR commodity in scope at the time of feeding (e.g., soybean meal that is traded). 

Traceability for Commodities from Multiple Countries 

Even in the case of complex supply chains, the new FAQ reiterates that maintaining accurate traceability of the relevant commodities is of utmost importance. For example, if a bulk shipment of soy is sourced from several plots of land across different countries, the operator, in this case, must ensure that the DDS for this shipment includes all relevant countries of production.  

This also entails supplementing the DDS with geolocation information for every single plot of land from all countries involved.  

Annual DDS Submission Now Allowed — But Only for Unchanged Origins

Operators can now file a single Due Diligence Statement covering up to 12 months, significantly easing the compliance process. However, this streamlined approach comes with a crucial caveat: it is only available if the products’ origins remain exactly the same throughout the year.  

Any change in the source, such as switching suppliers or adding new farms, requires a new DDS. As a result, this option will only be relevant for companies with highly stable and traceable supply chains, making it a practical solution for just a limited number of cases. 

New TRACES Limits and Flexibility for Corporate Groups 

The latest EUDR FAQ clarifies important technical limits for Due Diligence Statements (DDS) submitted via the TRACES system: each DDS can reference up to 2,000 other DDSs and is capped at a 25MB file size for geolocation uploads. A single DDS can include up to 200 product lines (distinct product entries). 

Additionally, the FAQ introduces new flexibility for corporate groups. Authorized representatives can now submit DDSs on behalf of multiple companies within a group. This streamlines compliance for large organizations and simplifies the process of referencing DDS numbers across entities. 

Tackling Government Laws Against Sharing Geolocation Data 

Operators in different countries might encounter strict government laws prohibiting the sharing of public geolocation data. However, the FAQ clearly states that the operators cannot rely on the existence of such laws to exempt them from conducting due diligence of relevant commodities. Hence, if operators are unable to provide the relevant data, they cannot place on, make available on, or export relevant products from the EU market. 

This also applies in case an upstream supplier is unable to provide the required information, thus prohibiting the commodity from entering the EU market.  

Effortless Traceability With osapiens HUB for EUDR 

EUDR sets strict, legally binding traceability and due diligence requirements. For companies placing relevant products on the EU market or exporting them, the ability to collect and verify detailed information, such as geolocation data, supplier information, and evidence of legal harvest, is not optional, but mandatory. Compliance requires not only accuracy but also process integrity and auditability.  

The osapiens HUB for EUDR is designed to help companies meet these regulatory obligations effortlessly by streamlining the entire compliance process within a single tool. It offers a wide range of features to simplify how you collect, manage, and utilize crucial data for traceability. 

• Simplified Data Collection: osapiens HUB for EUDR offers intuitive tools and interfaces to facilitate the collection of information from your supply chain partners, making the process less time-consuming and more accurate. 

• Multi-Country Traceability Support: Our system is equipped to handle complex supply chains involving multiple countries, allowing you to precisely geo-locate land plots, link products to their diverse origins and analyze deforestation data. 

• Batch and Composite Product Management: Whether you deal with bulk shipments or composite products with various components, osapiens HUB for EUDR helps you aggregate commodities or products used to create a new product and maintain clear traceability for each batch and material.  

• Seamless Referencing of Previous DDS: Downstream operators and non-SME traders can reference previous DDSs submitted by upstream operators, provided they validate those DDSs and ensure the information remains accurate and complete. 

• Automated Collection, Reporting and Documentation: Automatically request information, including geolocation data from suppliers for each purchase order, mitigate risks, and submit due-diligence statements. Generate the necessary reports and documentation, including geolocation information, required for your Due Diligence Statements in a format compatible with the EUDR Information System, and within the throughput, API, and geodata submission limits confirmed in the FAQ Version 4. 

Conclusion 

While the requirements may seem complex, osapiens HUB for EUDR provides an easy and efficient solution to ensure your products meet these standards.  

Be first. Be ready.  

Digitize your supply chain now to master EUDR compliance before it becomes a race. Join our next webinar to stay ahead of EUDR and turn traceability into a competitive advantage. 

• Monthly updates — what’s changed and what it means for your compliance strategy 

• Which supplier data you now need for full traceability 

• How automation and digital tools can make reporting much easier 

• Why acting now matters more than ever 

Join our next webinar (available in German) to stay ahead of EUDR and turn traceability into a competitive advantage.