EUDR Scope: What Businesses Need to Know

As the European Union takes a bold step toward environmental sustainability with the EU Deforestation Regulation (EUDR), businesses and global supply chains are bracing for significant changes. This groundbreaking regulation aims to curb deforestation by ensuring that only deforestation-free products can enter the EU market. But what does the EUDR scope really entail, and how will it impact your business operations?  

Understanding the full extent of this regulation is crucial, as non-compliance could result in severe penalties and lost market access. Understanding the scope of the EUDR is crucial for businesses, policymakers, and environmental advocates. 

According to WRI, almost 90% of the world’s forest loss is driven by the expansion of agriculture, thanks to growing consumer demand for commodities like coffee, cocoa, beef, soy, palm oil and timber. 

Key Takeaways 

• The EUDR Scope 

• EUDR Scope- Preparing for Impacts 

• Challenges for Businesses 

• Strategies for Compliance 

• TraceX EUDR Compliance Platform 

What is the EU Deforestation Regulation (EUDR)? 

The EU Deforestation Regulation is a regulatory framework designed to address the role of the EU in global deforestation and forest degradation. Enforced as part of the EU Green Deal, the EUDR is a crucial component of the EU’s broader strategy to tackle climate change and biodiversity loss. The regulation aims to ensure that products placed on the EU market are not linked to deforestation or forest degradation that occurred after 31 December 2020. 

The EUDR covers a range of commodities, including soy, palm oil, coffee, cocoa, and wood products. By targeting these key products, the regulation seeks to mitigate the EU’s impact on global deforestation and promote sustainable practices within the supply chain. 

The EUDR Scope 

Products Covered 

The EU Deforestation Regulation (EUDR) targets a critical list of commodities known for driving deforestation and forest degradation. This includes: 

• Soy: Predominantly used in animal feed and various food products, soy cultivation often leads to significant land clearing. 

• Palm Oil: Commonly found in a wide range of food items, personal care products, and biofuels, palm oil production is a major driver of deforestation. 

• Coffee: This globally traded commodity has substantial deforestation impacts, particularly in its major producing regions. 

• Cocoa: Essential for chocolate and confectionery, cocoa production is linked to deforestation in many growing areas. 

• Wood and Wood Products: Encompassing furniture, paper, and building materials, the wood industry contributes to deforestation through unsustainable logging practices. 

• Rubber: Used in various products including tires, rubber plantations have been a significant factor in deforestation. 

• Beef: The beef industry is a major driver of deforestation due to the extensive land required for cattle ranching. 

Understanding the EUDR’s scope is vital for businesses involved in these commodities, as it outlines strict requirements for demonstrating that their supply chains are deforestation-free. 

The specific list of products affected by the EU Deforestation Regulation (EUDR) is detailed in Annex I. Products not listed in Annex I are exempt from the Regulation’s requirements, even if they contain commodities covered by the Regulation. For example, soap, even if it contains palm oil, is not subject to the Regulation. Conversely, products listed in Annex I are only regulated if they contain or are made from the specified commodities. The prefix “ex” before an HS code in Annex I indicates that the product described is an “extract” from all items classified under that HS code. For example, HS code 9401 may cover various products, but only wooden seats are regulated. Products with HS codes not listed in Annex I, such as cars with leather seats or natural rubber tires, are also exempt, despite containing components derived from regulated commodities. 

Due Diligence Requirements 

Under the EUDR, businesses are required to undertake due diligence to ensure that the products they trade are not linked to deforestation or forest degradation. The due diligence process includes: 

• Supply Chain Mapping: Companies must map their entire supply chain to identify and assess risks associated with deforestation and forest degradation. 

• Geolocation Data: Firms need to provide geolocation data of the land where the commodities are produced to verify their sourcing practices. 

• Verification and Certification: Products must be verified through independent certification schemes or other credible methods to ensure they meet the EUDR’s requirements. 

Geographic Scope 

The EUDR applies to deforestation and forest degradation occurring in any country, regardless of where the deforestation takes place. This means that even if deforestation occurs outside the EU, products linked to such practices cannot be sold in the EU market. This global approach highlights the EU’s commitment to addressing deforestation on an international scale and promoting global sustainability. 

The Commission proposes a dynamic approach to regulating commodities under the EU Deforestation Regulation (EUDR), with a plan to periodically review and update the list based on new data. This approach will ensure that the Regulation adapts to evolving deforestation patterns. The Regulation is applied equally to products from both within the EU and outside of it, without any discrimination. It covers all products listed in Annex I, regardless of whether they are produced within the EU or imported. 

Reporting and Compliance 

Companies are required to submit detailed reports demonstrating compliance with the EUDR. These reports must include information about the due diligence process, risk assessments, and measures taken to mitigate deforestation risks. The EUDR mandates that businesses maintain accurate and up-to-date records to facilitate audits and inspections by regulatory authorities. 

The Subjective Scope 

The EUDR defines ‘operator’ as any natural or legal person engaged in a commercial activity who places relevant products on the market or exports them. Additionally, ‘traders’ are also required to comply with the Regulation. Traders are individuals or entities in the supply chain, other than operators, who make relevant products available on the market during their commercial activities. 

The Regulation applies to both large companies and SMEs. However, SMEs are granted an extended deadline until 30 June 2025 to meet their obligations, and they will have simplified requirements compared to larger entities. 

EUDR Scope – Preparing for Impacts 

As the EU marketplace is the second-largest global contributor to deforestation after China, the EUDR is poised to play a critical role in mitigating the EU’s impact on global deforestation and forest degradation. 

The Regulation is anticipated to reduce greenhouse gas (GHG) emissions and curb biodiversity loss over time. Additionally, the Commission has indicated that the EUDR could be expanded in the coming years to cover commodities and products from other vulnerable ecosystems, such as wetlands. 

The EUDR’s scope is already extensive. This regulation focuses on the environmental and social impacts of specific products throughout their value chains. The EU aims to drive meaningful change, encouraging companies to view compliance not merely as a regulatory obligation but as an opportunity to reassess their supply chains and make strategic improvements. 

Compliance will require more than just ticking boxes. The EUDR mandates that economic operators conduct thorough analyses of their supply chains to ensure that the products they market or export do not contribute to deforestation or forest degradation and are produced in accordance with the regulations of the countries of origin. 

With only 5 months remaining before these obligations come into full effect, companies within the scope of the EUDR should begin preparing now. They will need to address significant demands related to data management, supply chain due diligence, and essential systems and processes. Compliance is a one-way path, and regulatory requirements are expected to become even more stringent in the near future. 

Challenges for Businesses 

The EUDR presents several implications for businesses involved in the production, trade, and processing of commodities covered by the regulation: 

• Increased Operational Costs 

Complying with the EUDR may involve increased costs for businesses, including expenses related to supply chain mapping, geolocation data collection, and certification processes. Companies may need to invest in new technologies and systems to meet the regulation’s requirements. 

• Supply Chain Transparency 

The regulation necessitates greater transparency in supply chains. Businesses must work closely with suppliers and stakeholders to gather and verify information about the origin of their products. This increased transparency can lead to more robust and resilient supply chains. 

• Risk Management 

The EUDR requires companies to assess and manage risks associated with deforestation and forest degradation. Businesses must develop risk management strategies and implement measures to mitigate potential risks. This proactive approach can help companies avoid reputational damage and regulatory penalties.

Strategies for Compliance 

To effectively comply with the EUDR Scope, businesses should consider the following strategies: 

Invest in Technology 

Leveraging technology, such as blockchain and digital traceability solutions, can enhance supply chain transparency and facilitate compliance with the EUDR. Technology platforms can provide real-time data, automate reporting processes, and ensure the accuracy of geolocation information. 

Collaborate with Stakeholders 

Engaging with suppliers, industry groups, and certification bodies is crucial for achieving compliance. Collaborative efforts can help businesses address challenges, share best practices, and stay informed about regulatory updates and industry standards. 

Develop a Comprehensive Due Diligence Process 

Implementing a robust due diligence process involves mapping supply chains, assessing risks, and verifying compliance. Companies should establish clear procedures and protocols for due diligence to ensure consistent and effective implementation. 

Stay Informed and Adapt 

The regulatory landscape is continually evolving. Businesses should stay informed about changes to the EUDR and other relevant regulations. Adapting to new requirements and trends will help companies maintain compliance and remain competitive. 

How TraceX EUDR Compliance Platform Tackles the Challenges of EUDR Scope 

TraceX offers a comprehensive solution designed to navigate the complex landscape of the EU Deforestation Regulation (EUDR) scope.  

1. Comprehensive Coverage: The TraceX platform ensures all products listed in Annex I, including commodities like soy, palm oil, coffee, cocoa, wood, rubber, and beef, are tracked accurately. It accommodates the specific requirements of the EUDR, ensuring that all relevant products, whether produced in the EU or imported, comply with the regulation. 

2. Robust Supply Chain Transparency: With the EUDR requiring rigorous supply chain analysis, The platform provides end-to-end traceability of products. Our platform allows companies to map their entire supply chain, from raw materials to final products, ensuring transparency and adherence to EUDR regulations. 

3. Adaptable and Future-Ready: As the EUDR scope evolves and new commodities or products are potentially included, the platform is designed to adapt. Our system allows for regular updates and integrations, ensuring compliance with current and future regulatory changes. 

4. Efficient Data Management: Managing extensive data is a significant challenge under EUDR. The platform streamlines data collection and management, providing real-time insights and reports to facilitate compliance and reduce administrative burdens. 

5. Regulatory Compliance and Reporting: TraceX helps businesses meet EUDR’s rigorous compliance requirements through automated reporting and documentation. Our platform simplifies the process of generating necessary compliance reports and ensures that all documentation meets regulatory standards. 

6. Ease of Integration: Our platform integrates seamlessly with existing systems, minimizing disruption while enhancing compliance capabilities. This ensures that companies can quickly adapt their processes to meet EUDR requirements without significant operational changes. 

7. Support for SMEs: Recognizing that SMEs face different challenges, the platform provides tailored solutions that simplify compliance for smaller operators, making it easier for them to meet the EUDR requirements without extensive resources. 

Explore our EUDR Compliance Platform 

EUDR: Driving Sustainable Transformation in Global Supply Chains 

The EU Deforestation Regulation represents a significant step towards addressing global deforestation and promoting sustainable practices within supply chains. By understanding the EUDR scope and implementing effective compliance strategies, businesses can contribute to environmental conservation, enhance their market position, and navigate the complexities of the regulation. 

As the EUDR continues to shape the landscape of global trade and sustainability, companies must embrace transparency, invest in technology, and collaborate with stakeholders to achieve meaningful impact. The path to compliance may present challenges, but it also offers opportunities for growth, innovation, and positive change in the fight against deforestation.