EUDR

·

March 6, 2025

New EUDR Document - Scenarios for EUDR Compliance

Written by

Caroline Busse

MRV Carbon and Deforestation

The European Commission, in collaboration with the UN Environment Programme (UNEP-WCMC), prepared a document highlighting the key obligations of the EU Deforestation Regulation.

The due diligence obligations are compared by:

  • Type of company: operator or trader
  • Position in the supply chain: first placing on the market (upstream) or downstream
  • Size: non-SME or SME
  • Location: commodities produced inside or outside of the EU

Table 1: Overview of the level of the EUDR due diligence (DD) obligations

The document outlines 11 scenarios as examples that demonstrate how the rules apply to different products and supply chains:

  • Domestic Timber: Timber companies, saw mills and furniture companies must ensure logs, paper, or furniture meet deforestation-/ degradation-free and legal criteria.
  • Imported Paper for Newspapers: Paper importers must conduct due diligence, and downstream publishers must confirm due diligence was performed.
  • Beef Supply Chain: Cattle farms must ensure cattle are not raised on deforested land and are produced in accordance with the national legislation. Meat processors, tanneries and supermarkets need to ascertain that due diligence was exercised.
  • Palm Oil Processing: Palm oil refiners and cosmetic manufacturers must exercise due diligence and verify which products are relevant for DD under the EUDR.
  • Rubber & Tyre Manufacturing: Tyre companies importing vulcanised rubber or tyres must perform due diligence. Garages must keep records with details of their suppliers and buyers and references numbers of existing DDS.
  • Coffee: Coffee roasters and traders importing coffee beans in bulk containers may cover multiple batches with the same DDS for up to one year. Commodities need to be segregated from commodities of unknown origin and from non-deforestation-free commodities.
  • Cocoa: Importers and chocolate producers must maintain traceability and geolocation data. Cocoa processors and chocolate manufacturers may refer to existing DDS for prodicts already subject to DD.
  • Soy: Oilseed crushing facility importing bulk soybeans must conduct full due diligence and can refer to existing due diligence statements for processed products.

Table 2: Overview of which commodities are used in the supply chain-specific scenarios

Read the original report in full length here.

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ABOUT THE AUTHOR

Caroline Busse

CEO

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Caroline is an experienced data scientist with a management degree from TU Munich and a degree in earth observation from the University of Würzburg, which is co-chaired by the German Aerospace Center (DLR). She has worked as a data scientist in the areas of nature conservation and land use change monitoring at WWF, the German Centre for Integrative Biodiversity Research (iDiv), and at tech companies such as Celonis and Deloitte.

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