EUDR Due Diligence: Why Product Traceability Is the Hardest Requirement

Two delays. Same core obligation.

The EU Deforestation Regulation has been delayed twice. Originally due December 30, 2024. Pushed to December 30, 2025. Then pushed again to December 30, 2026 for large and medium operators under Regulation (EU) 2025/2650, published in the Official Journal on December 23, 2025. Small and micro operators have until June 30, 2027.

The delays have been welcomed by supply chains that weren't ready. But every legal analysis published since December 2025 carries the same message: the delays have not changed the core compliance obligation. Tracing commodities to the exact geolocation of the plot of land on which they were produced, demonstrating that those plots were not deforested after December 31, 2020, and documenting a full due diligence process remain the fundamental requirements of the regulation.

What changed in December 2025 is the structure of who is responsible for submitting what, with significant simplifications for downstream operators. What didn't change is the traceability requirement that makes the EUDR the most operationally demanding supply chain regulation the EU has ever enacted.

This article examines what the December 2025 amendments actually changed, why geolocation traceability is the compliance bottleneck that delays alone cannot solve, and what manufacturers need to build before December 30, 2026.

What Changed in December 2025: The Key Simplifications

Regulation 2025/2650 and the December 2025 amendments

Regulation (EU) 2025/2650 was published on December 23, 2025, following a provisional political agreement between the European Parliament and the Council on December 4, 2025. The amendments introduce three structural changes alongside the enforcement delay:

Downstream operator relief. This is the most operationally significant change. Previously, every operator and trader in the supply chain was required to submit a due diligence statement (DDS) for products they placed on or made available on the EU market. Under the amended regulation, only the first operator placing a relevant product on the EU market must submit a full DDS. Downstream operators (manufacturers and retailers that subsequently commercialise the product) no longer need to submit their own DDS. They must, however, collect and retain the reference number of the DDS submitted by the upstream operator, and they remain responsible for not dealing with non-compliant products.

Simplified declarations for small and micro primary operators. Micro and small primary operators in low-risk countries may submit a one-off simplified declaration rather than a full DDS. This reduces the compliance burden for small-scale farmers and processors while preserving the traceability chain.

Printed products removed from scope. Books, newspapers, printed pictures, and other printed products falling under HS Chapter 49 have been excluded from the EUDR's scope, reflecting Parliament's assessment that printed products present limited deforestation risk.

The April 2026 Simplification Review

By April 30, 2026, the European Commission was required to present a report assessing the EUDR's administrative impact, particularly for micro and small operators. Commissioner Jessika Roswall confirmed in January and February 2026 that the Commission does not favour another core text reopening, but is committed to using the April 2026 review for "targeted tweaks to simplify implementation."

These tweaks are expected through the "April 2026 Simplification Package," consisting of:

• Revisions to EUDR FAQs and Guidance documents
• Adoption of a Delegated Act amending Annex I (the listing of in-scope products), potentially removing leather and possibly other products following industry lobbying
• Revisions to the Implementing Regulation on the Information System (the IT platform for DDS submission)

The April 2026 package will not alter the fundamental EUDR compliance obligations. Geolocation traceability, deforestation-free demonstration, legal compliance, and DDS submission by first-placing operators remain intact.

Country risk classification system (Implementing Regulation 2025/1093)

Published in April 2025, the Implementing Regulation establishes a country benchmarking system that classifies countries as low, standard, or high risk for deforestation in relation to each commodity. This classification determines the intensity of due diligence required:

• Low risk countries: Operators and traders may submit a simplified DDS without a full risk assessment. Products from low-risk countries are subject to lighter scrutiny from competent authorities.
• Standard risk countries: Full due diligence required: information collection, risk assessment, and risk mitigation.
• High risk countries: Full due diligence required, with enhanced scrutiny from competent authorities and higher frequency of checks.

The risk classification is commodity-specific and country-specific. A country may be low risk for coffee but standard risk for soy. The full risk classification system was published on 22 May 2025 as Implementing Regulation (EU) 2025/1093. Companies should now map their supply chains against it, as the Commission has announced a first review of the classifications in 2026. Companies should monitor its publication closely, as the classification directly determines the due diligence effort required for each supply chain.

The Seven Commodities in Scope and Their Derived Products

The EUDR applies to seven commodity groups and their derived products:

Cattle: Beef and veal, leather, hides, live bovine animals, and other derived products (gelatin, tallow, collagen from cattle sources).

Cocoa: Cocoa beans, butter, powder, paste, and chocolate and food preparations containing cocoa.

Coffee: Roasted and unroasted coffee, including decaffeinated, coffee extracts, and preparations.

Palm oil: Crude and refined palm oil, palm kernel oil, glycerol, and oleochemicals derived from palm sources.

Soya: Soya beans, soya flour, soya bean oil, and soya-based food preparations.

Wood: Round wood, sawn wood, wood fuel, wood-based panels, pulp, paper, paperboard, printed products (now removed), furniture, and wood charcoal.

Rubber: Natural rubber, latex, rubber products including tyres, gloves, hoses, and conveyor belts.

The scope is broad and catches many manufacturers who do not consider themselves agricultural commodity buyers. A furniture manufacturer sources wood. An automotive parts manufacturer uses rubber in seals and tyres. A food company uses palm oil as an ingredient. A cosmetics company uses palm-derived fatty acids. Each of these represents an EUDR obligation that requires supply chain traceability to the plot of land level.

Why Geolocation Traceability Is the Hardest Requirement

1. Plot-level traceability requires data that has never been collected

The EUDR requires operators to collect and submit geographic coordinates (polygon or point data) identifying the specific plot of land on which each commodity was produced. For timber, this means the forest parcel. For cattle, the ranch. For soy and palm oil, the agricultural plot. This must be provided for every batch of relevant product placed on the EU market.

In commodity supply chains, raw materials are aggregated at the first point of processing (the mill, the slaughterhouse, the trading house) and then blended, processed, and shipped as undifferentiated bulk. By the time a raw material reaches a European manufacturer, it may represent the output of hundreds of farms across multiple countries. No single entity in the chain maintained parcel-level geographic records because no regulation previously required it.

Collecting this data retrospectively is not just difficult. For many agricultural supply chains, it is impossible without a complete structural redesign of sourcing relationships and data collection systems.

2. The deforestation cut-off date creates a retroactive compliance problem

Products must demonstrate they were produced on land that was not deforested after December 31, 2020. This means that a plot of land cleared between 2021 and 2024 produces non-compliant commodities under the EUDR, even if the clearing was legal under the country of origin's laws. Manufacturers buying from these plots have no pathway to compliance other than switching sourcing.

Identifying which plots in a commodity supply chain were cleared after December 31, 2020 requires satellite imagery analysis or verified land registry data for every plot in scope. For small-holder dominated supply chains (coffee, cocoa), where millions of individual farms feed into a single processing facility, this analysis is a data engineering challenge at a scale that most companies haven't attempted.

3. Multi-tier supply chains dilute visibility at every step

A typical agricultural commodity supply chain for chocolate runs: cocoa farmer, cooperative, local processor, international trader, cocoa butter refiner, chocolate manufacturer. At each transfer point, product from multiple sources is commingled. By the time the chocolate manufacturer receives cocoa butter, the lot may represent dozens of cooperatives, hundreds of farms, and thousands of individual plot transactions.

The EUDR requires the first EU operator placing this product on the market to trace back to the farm level. For a company several steps removed from primary production, this requires either direct relationships with every tier of the supply chain (rarely achievable at scale) or reliance on certification schemes and third-party verification (which must genuinely trace to plot level, not just to a geographic region or cooperative boundary).

4. The IT system for DDS submission has been a persistent bottleneck

The EU TRACES NT system for DDS submission was not ready for the original December 2024 deadline. It was not fully operational for the December 2025 deadline (part of the reason for the delay). The December 2025 amendments included a requirement for competent authorities to report significant IT system disruptions to the Commission, signalling that system reliability remains a concern.

The April 2026 Simplification Package includes revisions to the Implementing Regulation on the Information System. Until the system is operational and tested at scale, companies cannot validate that their DDS submissions will be processed correctly, making parallel compliance preparation with paper documentation essential.

5. Supplier readiness is uneven across commodity regions

The geolocation data collection burden falls primarily on upstream suppliers: the farms, cooperatives, and first processors in producing countries. These suppliers range from large, professionally managed agricultural enterprises (often in Brazil, Malaysia, and Indonesia) to subsistence-scale smallholders in West Africa and Southeast Asia.

Large enterprises in major producing countries are increasingly equipped to provide EUDR-compliant data, having invested in farm mapping and digital documentation systems. Smallholder-dominated supply chains, particularly for cocoa in West Africa and coffee in Central America, face significant capacity gaps. Cooperative structures and aggregators in these regions are working with NGOs, governments, and buyers to build mapping capabilities, but the work is incomplete.

A manufacturer whose supply chain passes through these regions faces a practical reality: they can request geolocation data from their suppliers, but if the supplier cannot produce it, the manufacturer must either wait for the supplier to develop the capability, source from a different supplier who has it, or accept that the product cannot be placed on the EU market compliantly.

What the December 2025 Downstream Operator Change Means in Practice

The downstream operator simplification is genuinely significant for manufacturers who are not the first to place a relevant product on the EU market. For a food manufacturer buying cocoa butter from an international trader who is the first EU importer, the food manufacturer:

• Does not need to submit its own DDS for the cocoa butter or cocoa-containing products
• Must collect and retain the DDS reference number from the upstream operator -  this obligation applies to the first downstream operator only; further downstream entities are not required to collect reference numbers. 
• Must not deal with non-compliant products even without submitting a DDS
• Must conduct proportionate due diligence to satisfy itself that the upstream operator's DDS is credible

The practical implication: downstream manufacturers are relieved of DDS submission but not of supply chain oversight. They need to build supplier qualification processes that verify DDS submission and assess the credibility of upstream due diligence. A manufacturer who assumes that receiving a DDS reference number discharges all EUDR obligations is misreading the regulation.

Building EUDR Traceability That Holds Up

1. Map every in-scope commodity across your supply chain

Identify every product you place on the EU market that contains or consists of an in-scope commodity: beef-derived gelatin in food products, palm-derived fatty acids in personal care formulations, natural rubber in seals and gaskets, wood in packaging, soy lecithin in processed foods. The scope is wider than most procurement teams recognise.

2. Identify your role in each supply chain

For each in-scope commodity, determine whether your company is a first-placing operator (directly importing and placing EUDR goods on the EU market) or a downstream operator (receiving from a first-placing operator). Your DDS submission obligations, and the due diligence depth required, differ significantly between these roles.

3. Collect geolocation data through supplier engagement

Issue geolocation data requests to Tier-1 suppliers for each in-scope commodity. For direct importers, request GPS coordinates (polygon or point) for each production plot, with supporting documentation of legal land use and deforestation-free status as of December 31, 2020. For downstream operators, request DDS reference numbers from the first-placing operator.

4. Assess country risk once the classification system is published

Once the EU's country risk classification is published in full, map your commodity supply chains against the risk tiers. For low-risk country sourcing, simplified due diligence applies. For standard and high-risk sourcing, full risk assessment, mitigation, and DDS preparation are required.

5. Register and test with the TRACES NT system

Register in the EU TRACES NT system as a EUDR operator, trader, or non-SME downstream operator before the December 2026 deadline. Do not wait for the April 2026 Simplification Package to finalise system updates before registering. The system requires testing with actual supply chain data to identify integration issues that cannot be resolved in the weeks before the deadline.

A Self-Check for EUDR Readiness

Six questions to pressure-test your compliance position:

• Commodity scope: Have I identified every product I place on the EU market that contains or consists of cattle, cocoa, coffee, palm oil, soya, wood, or rubber, including derived ingredients and components?
• Role determination: For each in-scope commodity, have I established whether I am a first-placing operator (DDS submission required) or a downstream operator (DDS reference number collection required)?
• Geolocation data: Am I collecting plot-level geographic coordinates from suppliers for in-scope commodity production, or relying on supplier attestations without location data?
• Deforestation cut-off: Have I assessed whether any production plots in my supply chain were cleared after December 31, 2020?
• Country risk: Have I mapped my supply chain sourcing against the published EU country risk classification (Regulation 2025/1093)? 
• IT system readiness: Is my organisation registered in TRACES NT and has my team tested DDS submission workflows with actual supply chain data?

If more than two answers reveal gaps, the data collection and system integration work required between now and December 30, 2026 is more substantial than a normal compliance preparation cycle can absorb.

Where Regilient fits in

EUDR compliance is not a regulatory interpretation challenge. It is a supply chain data collection challenge at a depth that most compliance programmes have never attempted. The geolocation, deforestation-free status, and legal compliance data the EUDR requires doesn't exist in most manufacturing compliance systems today, and collecting it manually across multi-tier agricultural supply chains is not operationally viable at scale.

Regilient's agentic sustainability platform extends supply chain data collection into the traceability requirements that the EUDR demands:

• Commodity scope mapping that identifies every in-scope product and ingredient across a manufacturer's portfolio, including indirect and derived commodity content
• Supplier geolocation data collection workflows with structured requests for plot-level GPS coordinates, land registry documentation, and deforestation-free evidence
• DDS reference number management for downstream operators, tracking upstream operator submissions and maintaining the auditable documentation chain required for competent authority checks
• Country risk integration that maps supply chain sourcing against the EU's commodity-country risk classification, adjusting due diligence depth by risk tier
• TRACES NT submission support with structured data formats aligned to the DDS information requirements and system validation rules

The EUDR's core traceability requirement has survived two delays and a round of simplifications. It will survive the April 2026 Simplification Package. The companies that used the delay to build geolocation data collection infrastructure and supply chain mapping capabilities will comply in December. The companies that treated each delay as another year to wait will face the same data gap in December 2026 that they faced in December 2024.

Book a Regilient demo to see how agentic supply chain traceability collects the plot-level data and DDS documentation your EUDR programme requires before the December 30, 2026 deadline.

Regilient provides agentic sustainability software for product compliance, supplier engagement, and regulatory intelligence across REACH, RoHS, PFAS, CMRT, SCIP, and global chemical regulations.