From 30 December 2026, the EU Regulation on deforestation-free products, known as the EUDR, will start to apply to large and medium operators. For most micro and small operators, application is scheduled for 30 June 2027.
The measure applies to products placed on the European Union market, sold within the EU or exported from the EU when they fall within the scope of the relevant commodities and relevant products associated with deforestation risk.
For the food sector, the main areas of attention include coffee, cocoa, palm oil, soy, cattle and several derived products, including chocolate, bakery products, spreads, compound ingredients and semi-finished products.
What the EUDR requires
According to the European Commission, products covered by the Regulation must be "deforestation-free", meaning that they are not associated with deforestation or forest degradation, and must be produced in accordance with the relevant legislation of the country of production.
In practice, simply declaring the origin of the raw material will not be enough. The operators involved will need to demonstrate, through a due diligence system, that the relevant commodities used do not come from land that has been subject to deforestation after 31 December 2020.
Which food products may be affected
In the food sector, the Regulation may affect several supply chains. The most relevant include coffee, cocoa, chocolate, spreads, sweet snacks, bakery products, preparations containing palm oil, soy-based ingredients and products linked to the cattle supply chain.
The issue does not concern only bulk commodities. A processed product may also fall within the scope of the EUDR if it contains or has been made using relevant commodities or relevant products listed in Annex I of the Regulation. For this reason, the topic concerns not only importers and traders, but also producers, processors, brand owners, distributors and operators exporting food products from the EU.
Due diligence, traceability and geolocation
One of the most important aspects is traceability. Upstream operators in the supply chain will need to collect information on the product, quantity, country of production, suppliers and the areas where the relevant commodities were grown, harvested or raised.
The European Commission also identifies the geolocation of the plots of land where the relevant commodities were produced as a key requirement. If the required information cannot be collected, the relevant product cannot be placed on the EU market or exported.
Due diligence involves three main steps: information collection, risk assessment and, where necessary, risk mitigation measures. Before being placed on the market or exported, relevant products must be covered by a due diligence statement (DDS) or by a simplified declaration, submitted through the EUDR Information System.
Why it matters for food companies
For food companies, the EUDR may affect supplier selection, technical specifications, purchase contracts, technical and commercial product documentation and continuity of supply.
A chocolate producer, for example, will need to verify the documentation relating to the cocoa used. A company producing biscuits, spreads or snacks will need to check whether any palm oil or cocoa used as an ingredient meets the new criteria. A coffee importer will need to ensure that the raw material is accompanied by the information required to comply with the Regulation.
For buyers and distributors, the issue therefore also becomes commercial: products that are not properly documented may face difficulties in accessing the European market or being distributed to more structured customers.
What companies should do now
In view of the entry into application, companies should start mapping the products and ingredients potentially affected by the EUDR. It is useful to check which relevant commodities and relevant products fall within the Regulation, which suppliers are involved and what information is already available along the supply chain.
Particular attention should be paid to cocoa, coffee, palm oil and soy, especially when these ingredients are present in processed products or complex recipes. Early preparation can reduce the risk of delays, sudden documentation requests or order management problems.
What checks companies need to carry out
EUDR-compliant due diligence is not a simple supplier self-declaration. Companies must collect, verify and keep sufficient information to demonstrate that the relevant product or ingredient does not come from land subject to deforestation after 31 December 2020 and that it was produced in accordance with the relevant legislation of the country of production.
The first step is supply chain mapping. For each product or ingredient covered by the Regulation, the operator must identify the supplier, the country of production, the quantity, the relevant commodity involved and the plots of land from which the commodity used originates.
Geolocation is one of the central elements. The company must be able to trace the plots of land where cocoa, coffee, soy, palm oil or other commodities covered by the Regulation were produced. In the case of products containing commodities produced in several areas, the assessment must cover all the different origins or geolocations involved.
How to verify whether land has not been deforested
To understand whether land has not been subject to deforestation, especially when it is located in non-EU countries, knowing the country of origin is not enough. The commodity must be linked to one or more specific plots of land and this information must be compared with reliable data on forest status and land use.
In practice, companies can use different sources: geographic coordinates of the plots of land, forest maps, satellite images, national or regional public data, cadastral or administrative documents, local authorizations, independent audits, geolocated photographs and information collected directly from producers, cooperatives or exporters.
Maps and geospatial tools can help identify possible risk signals, but they do not replace the operator's responsibility. Verification must be consistent with the specific product and the actual supply chain. If a map indicates a possible overlap with forest areas, or if supplier data is incomplete or contradictory, the company must investigate further before proceeding.
Risk assessment: what needs to be checked
After collecting the information, the operator must assess the risk of non-compliance. Elements to consider include the risk level assigned to the country or area of production, the presence and status of forests, the prevalence of deforestation or forest degradation, the risk of illegal production, the complexity of the supply chain and the source, reliability and validity of the documents received.
Another important aspect concerns the supplier. The company should verify whether the counterparty is able to provide complete and verifiable documents, whether there are previous cases or substantiated concerns linked to illegal practices, deforestation or forest degradation, and whether the supply chain includes intermediate steps that make it difficult to trace the actual origin of the commodity.
In countries or areas with a higher risk of corruption, document or data falsification, weak law enforcement, conflict or human rights violations, formal documentation may not be sufficient. In these cases, additional checks, independent surveys or audits or more detailed information on production areas may be necessary.
What happens if the risk is not negligible
If doubts emerge from the assessment, the company must adopt risk mitigation measures. These may include requesting additional information, data or documents, carrying out more in-depth checks on the supplier, using third-party verification, conducting supply chain audits, adopting more precise traceability systems or supporting producers in improving data collection.
The objective is to reach a level of no or only negligible risk. If this result cannot be achieved, the relevant product should not be placed on the EU market or exported from the European Union.
Why preparation must start with suppliers
For many food companies, the critical point will be the quality of the information received from suppliers. A technical sheet or a generic declaration of origin may not be enough. For this reason, it will be important to request structured data on the origin of the commodity, the geolocation of the plots of land, the documents and the checks already carried out upstream.
