Most compliance work asks what you did to a product. The EU Deforestation Regulation asks something harder: what happened to a piece of land, on the other side of the world, before your ingredient existed. For a manufacturer buying palm oil, cocoa butter or soy lecithin through two or three intermediaries, that is a records problem long before it is a sourcing problem.
What EUDR is actually asking
The regulation covers seven commodities and the products derived from them. To place them on the EU market, you need to show two things: that the commodity is legally produced in its country of origin, and that it is deforestation-free — grown on land not deforested or degraded after 31 December 2020.
The seven commodities:
That last box is the one that catches food manufacturers out. You may never buy a commodity in its raw form and still be squarely in scope. Palm derivatives in a coating, cocoa mass and cocoa butter, soy protein and soy lecithin, coffee extract, gelatine and beef, and wood-based cartons and paper packaging — all derived, all covered.
The Due Diligence Statement
The evidence takes the form of a Due Diligence Statement, submitted to the EU information system, which returns a reference number and a verification number. Those numbers are the currency of EUDR: they travel down the supply chain, so a manufacturer buying a covered ingredient is often not submitting anything themselves.
In practice you will be in one of two positions for any given batch:
Your supplier has already submitted and gives you a reference and verification number. Your job is to capture those against the batch and keep them retrievable.
You submit yourself, which means holding production country, plot geolocation, country risk level and a deforestation-free declaration.
Why geolocation is the sharp end
EUDR is assessed per plot of land, not per supplier. A self-submitted statement needs the latitude and longitude of the plots where the commodity was produced, so the deforestation-free claim can be checked against satellite forest-cover records for the period after the cut-off. “We buy from a certified supplier” is a sourcing policy; coordinates are evidence.
Country risk changes the workload, not the duty
Producing countries are classified as low, standard or high risk, and the classification governs how much assessment and mitigation you must do — simplified due diligence for low risk, the full exercise for standard and high. What it never removes is the duty to collect the information and hold the statement.
Getting your records ready
The work divides cleanly into things to do once and things to do per batch. Once, per ingredient:
- Screen your ingredient list against the seven commodities — including derivatives, and including packaging.
- Record which commodity each covered ingredient relates to, so the obligation is attached to data rather than memory.
- Ask every supplier of a covered ingredient, in writing, whether they will provide a DDS reference or expect you to submit.
- Note the production country and its risk classification for each supply route.
Then, per batch received:
- Capture the DDS reference and verification number, or the geolocation and declaration set if you are submitting.
- Attach the supporting evidence to the batch, not a shared drive folder.
- Keep the statement retrievable by batch number, so a customer question resolves in minutes.
The bottom line
EUDR does not reward good intentions about sourcing; it rewards records tied to specific plots of land and specific batches. Manufacturers who already run tight batch traceability have most of the structure — the new part is a due diligence record hanging off each covered batch, and knowing at a glance which ones are still missing it.
If you also sell into the EU, it is worth reading this alongside the packaging regulation, PPWR — the two land on the same procurement conversations, and wood-based packaging sits in both.
Frequently asked questions
Which commodities does EUDR cover?
Seven: soy, palm oil, cocoa, coffee, rubber, cattle and wood — plus derived products. For food manufacturers that usually means the derivatives: palm fractions, cocoa mass and butter, soy protein and lecithin, coffee extracts, beef and gelatine, and wood-based cartons and paper.
What is a Due Diligence Statement?
The declaration submitted to the EU information system confirming a consignment is deforestation-free and legally produced. It carries a reference number and a verification number, which can be passed down the supply chain — so you may be recording your supplier's rather than submitting your own.
What is the EUDR cut-off date?
31 December 2020. The commodity must come from land not subject to deforestation or forest degradation after that date. Because the test is applied to the land, evidence is tied to the specific plot.
Why is geolocation data required?
Compliance is assessed per plot, not per supplier. A submission needs the latitude and longitude of the production plots so the claim can be checked against satellite forest-cover records for the period after the cut-off.
Does EUDR apply to UK manufacturers?
It applies to anyone placing covered products on the EU market or exporting from it, so a UK manufacturer selling into the EU is in scope. Those selling only domestically are still routinely asked for the same evidence by EU-facing customers, so most keep the records anyway.
Know which batches are missing a DDS.
See how Prodara's EUDR Compliance screen tracks due diligence across every covered ingredient.