First, a shifting playing field
This project started in the fall of 2025 and ran till the spring of 2026, which meant we were aiming at a moving target: the European Commission would not present its EUDR simplification package until 4 May. Every time something shifted in the run-up to that date – the deadlines, or the precise requirements for companies further down the chain – what the law meant for Agricon shifted with it. That made the challenge greater than anticipated.
1. Scoping as the foundation
Completing an EUDR project in roughly three months takes effort above all at the start. First we drew up an inventory. Which companies make up Agricon, and how many employees and how much turnover does each of them have? That determines both your EUDR obligations and your deadline – 30 December 2026 for large and medium-sized enterprises, 30 June 2027 for small and micro-enterprises. The next question concerned the products: which ones does the group buy, which does it sell, and do they come from Europe or not?
That last question is the decisive one, because the law places the greatest responsibility on the companies that first bring a product into Europe. Anyone reselling it further down the line has considerably less to do.
At Agricon, products fall under the EUDR on both the buying and the selling side, but the group imports nothing from outside Europe. Agricon sits further down the chain, and there the obligation comes down mainly to record-keeping. Alongside the official details of your customers and suppliers, you keep the reference numbers of the declarations in which earlier links in the chain demonstrate that no forest was cleared for their products.
2. From gaps to priorities
Once the scoping is settled, the process moves quickly. The gap analysis set two things side by side: the efforts the group already makes today, and what the EUDR asks on top of that. For every missing measure, we estimated how much work it would take.
Two considerations determined the order of those measures, and with it the action plan. We gave priority to steps that save a great deal of work later on, such as a single choice that settles several product flows at once. Agricon also needed to inform customers and suppliers quickly: customers, to show them the company had the matter under control; suppliers, to give them enough time to gather the data requested. That last part proved no small task, so the information came in piecemeal – another reason why this project was more demanding than expected.
3. A tailored handbook
The action plan set the contents of a practical handbook. It runs to no more than fifteen pages and deliberately contains no summary of the legal text. It starts from the moments at which Agricon comes into contact with the EUDR, and describes what has to happen at each of them:
- which purchases and sales fall under the law and which do not;
- which information has to go into the register, and who maintains it;
- which information you request from a new supplier and provide to a customer who asks questions;
- what you check before considering a new product or a new market;
- who the point of contact is for borderline cases.
“We wanted a handbook that could be broken into parts, tailored to the people who actually work with it,” Nicolas Crins explains. “Every employee should be able to find and understand the section about their own job easily, and know who to turn to with questions. A fifty-page document that nobody reads does not move a company forward.”
That is exactly the difference from a standard document summarising the legislation. The rules are the same for everyone, but precisely which products you buy and sell – and who in your company has to act on them – differs from one business to the next.
4. Embedding the agreements
Agricon is now approaching its own customers and suppliers to get them moving, and is reviewing its contracts with those suppliers. Giving the EUDR agreements a fixed place in day-to-day operations, so that they come into play automatically with every purchase and every sale – that is the next step.
