The EUDR is based on the duty of care of every company. Companies that are subject to the regulation are required to carry out a thorough risk analysis across their entire value chain. These six steps will help you take a structured approach to EUDR implementation:

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1. Analyse your obligations

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Companies often start collecting data too quickly, even before they fully understand their legal obligations. Therefore, you should first determine your role under the EUDR:

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• Operator: your company places a product on the European market for the first time or exports it.
• Trader: your company sells a product that has already been placed on the market by other actors in the value chain, such as wholesalers and supermarkets.
• SME or non-SME: SMEs meet at least two of the following criteria: balance sheet total up to €25 million, net turnover up to €50 million, average number of employees up to 250.

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Each role comes with specific obligations and exemptions. In certain situations, EUDR requirements are less onerous for SMEs.

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2. Define your scope

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Depending on how you define your scope, data collection may become too broad (and therefore inefficient) or too narrow (and therefore incomplete). Early in the process, you should clearly determine:

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• which of your products or raw materials fall under the EUDR (using HS codes);
• whether risk commodities appear further upstream in your value chain, such as cocoa contained in a semi-finished product you purchase;
• how far upstream you need to trace your value chain; often this involves suppliers of suppliers, with whom you may not yet have a direct relationship.

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3. Engage your stakeholders

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Much of the required data comes from suppliers and partners. You should engage in dialogue with them at an early stage:

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• Clearly explain to non-EU suppliers, or those less advanced in their journey, what the EUDR is and what the purpose of the legislation is.
• Clarify which data are required, how they will be used, and how confidentiality will be safeguarded. Schedule a meeting to explain the questionnaire you have sent out.
• Consider investing in capacity building for critical suppliers, coaching, and/or collaboration with sector initiatives for suppliers that do not yet use the required systems.

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The earlier you actively involve your suppliers, the better you will be able to assess the workload and potential bottlenecks.

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4. Use the right tools

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To comply with the EUDR, you must, among other things:

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• collect geolocation points;
• carry out risk analyses;
• link all information to product flows;
• submit due diligence statements in an EU-wide system.

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Manual data processing is seldom scalable and is also prone to errors. Digital tools make your process more efficient and reliable. Consider investing in specialized EUDR software, or broader ESG software that can also be used to monitor other sustainability regulations, such as the CSRD and CSDDD.

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How to prepare your organisation forthe EUDR

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5. Optimize your governance

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The EUDR affects multiple departments, from sales and finance to sustainability, legal, and IT. Therefore, you should ensure a robust governance structure:

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• Set up a multidisciplinary EUDR team that brings together all relevant expertise.
• Clearly define roles and responsibilities: who requests data, who performs risk analyses, who approves statements?
• Establish a clear reporting line to management, particularly in view of the substantial penalties (up to 4% of annual turnover in case of non-compliance).

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Formalize this approach in an internal policy, such as a due diligence policy or deforestation policy. This not only supports implementation but also demonstrates to customers and auditors that you work in a structured and transparent manner. In doing so, you build trust and avoid greenwashing.

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6. Be prepared for non-compliance

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Even with thorough preparation, some suppliers may fail to provide data (on time) or may not meet EUDR requirements. Therefore, you should put an escalation procedure in place for non-compliance:

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• Who requests additional documentation?
• Who engages in dialogue with which supplier?
• When do you opt for an on-site audit at supplier level?
• When do you decide to replace a supplier?

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This helps you avoid ad hoc decisions and ensures consistent and transparent action.