EUDR Compliance for Composite Products: 5 Real-World Scenarios Explained

EUDR Compliance for Composite Products requires operators to meet due diligence and information requirements for every component containing relevant commodities. In the EU Deforestation Regulation, a composite product is non-compliant if even one-part lacks required data—such as geolocation, species identification, or proof of deforestation-free sourcing. The five real-world scenarios illustrate both compliant cases (all parts documented and covered by valid Due Diligence Statements) and failures caused by missing geolocation, unknown species, or links to post–cut-off deforestation. For compliance, supply chain traceability must extend to all components, ensuring each meets Article 3, 9, 10, and 11 requirements. 

The EU Deforestation Regulation (EUDR) is reshaping global trade for agricultural and forest-based commodities. By December 30, 2025 (or June 30, 2026, for SMEs), every operator placing goods on the EU market must prove their products are deforestation-free, legally sourced, and fully traceable—right down to plot-level geolocation. 

While challenging for single-origin goods, composite products—items made from multiple components like plywood, chocolate bars, or office furniture—pose a far greater compliance headache. A single non-compliant component can render the entire product unmarketable in the EU, regardless of the status of the other parts. 

The stakes are high: one missing geolocation, an unidentified species, or an undisclosed deforestation risk can halt shipments, trigger fines, and jeopardize EU buyer relationships. This article uses five real-world scenarios to show exactly how due diligence applies to composite products under the EUDR—and how to avoid costly mistakes. 

Key Takeaways 

• Composite products—goods made from multiple relevant commodities—face heightened compliance challenges under the EU Deforestation Regulation (EUDR) due to complex, multi-tier supply chains. 

• Five real-world scenarios show recurring patterns: missing geolocations, unknown species, incomplete DDS referencing, and inconsistencies in supplier data often cause compliance failures.  

• Successful cases highlight thorough due diligence for every component and effective use of existing DDS where verified. 

• Technology is the key enabler—traceability platforms like TraceX combine geo-tagging, digital DDS automation, and supplier risk scoring to manage complexity, ensure deforestation-free and legal sourcing, and safeguard EU market access. 

Understanding EUDR Compliance for Composite Products 

What are Composite Products under EUDR? 

In EUDR terms, composite products are goods made from multiple components—often sourced from different regions, species, and supply chains—where each component may contain one or more relevant commodities (timber, cocoa, coffee, palm oil, rubber, soy). Examples include plywood, cocoa-based confectionery, and office furniture. 

Due Diligence and Article References 

Compliance hinges on the Information Requirements (Article 9) and Due Diligence obligations (Articles 8–11). Operators must provide: 

• Country of production and plot-level geolocation for every relevant component. 

• Evidence of legal harvest/production and deforestation-free status. 

• Documentation that is verifiable, consistent, and linked to Due Diligence Statements (DDS) for all parts. 

The Compliance Risk Multiplier 

With composite products, risk compounds. Even if 95% of components are fully compliant, a single non-compliant part—whether due to unknown geolocations, missing species identification, or deforestation after the cut-off date—can make the entire product ineligible for the EU market. 

Most EUDR discussions focus on primary commodities, but composite goods are the real compliance minefield—they require component-level transparency, integrated traceability, and a system that can link multiple DDS without breaking the audit trail. Forward-looking operators are now investing in digital supply chain mapping tools to eliminate these gaps before the December 2025 enforcement deadline. 

Want to master the due diligence process under the EU Deforestation Regulation? Explore our expert blogs for actionable insights: 

• [EUDR Due Diligence Explained] – A step-by-step guide to meeting Articles 8–11 requirements with confidence. 

• [Real-World Due Diligence Examples] – Case studies showing what compliance looks like (and what causes failure) in practice.

5 Real World Scenarios 

Scenario 1 – Cocoa-Based Confectionery (Non-Compliant Due to Deforestation Risk) 

The main product in question is cocoa-based confectionary (HS 1806), weighing 900 kg. 

• The operator did perform due diligence (DD) for the product, but could not confirm it was deforestation-free as required under Article 3(a) of the EUDR. 

• This triggered a prohibition: under the Regulation, a product cannot be placed on the EU market if any part of it fails to meet deforestation-free or legal production standards. 

Component-Level Assessment 

The confectionary is a composite product containing three cocoa-derived components: 

Component: Cocoa Butter 

HS Code 1804 

DD Status: Yes — All geolocations known, DDS referenced and verified 

Compliance Outcome: Compliant 

Component : Cocoa Paste 

HS Code 1803 

DD Status: Yes — All geolocations known, DDS referenced and verified 

Compliance Outcome: Compliant 

Component: Cocoa Powder 

HS Code 1805 

DD Status: All geolocations known, but DD revealed some farms had deforestation after cut-off date. 

Compliant Outcome: Non-Compliant

Why the Entire Product Failed 

• Article 3(a) states that relevant products (and any parts of them) must be deforestation-free after the cut-off date. 

• Even though cocoa butter and cocoa paste met requirements, the cocoa powder component contained raw material from farms that were deforested after the cut-off date. 

• EUDR requires all relevant parts of a composite product to be compliant — one non-compliant part makes the entire product prohibited. 

Compliance Lesson 

• Composite products must have due diligence and DDS coverage for every single relevant component. 

• One high-risk or non-compliant ingredient blocks the entire product from EU market entry. 

• This case highlights the importance of plot-level traceability and component-level supplier vetting. 

Scenario 2 – CKD Office Furniture (Fully Compliant) 

This scenario is an example of full EUDR compliance for a composite product — in this case, CKD (completely knocked down) office furniture — where both the final product and its individual components meet the due diligence and information requirements. 

1. Due Diligence on the Final Product 

• The operator carried out due diligence in line with Article 8 of the EUDR, meeting the information requirements in Article 9. 

• A Due Diligence Statement (DDS) was submitted for the product as a whole. 

• This means the operator collected, verified, and assessed the required data (origin, species, geolocation, legality) and found no risk of non-compliance. 

2. Component-Level Verification 

Since the furniture is a composite product, each component also needed to meet EUDR requirements: 

• Core (Particle Board – HS 4410) 

• Species: Sitka spruce (Picea sitchensis) 

• Origin: EU Member State 

• Sourcing: Multiple plantations with all geolocations known. 

• DDS: Yes — referenced an existing DDS, confirming proper due diligence had already been exercised. 

• Face & Back (Veneer – HS 4408) 

• Species: European beech (Fagus sylvatica) 

• Origin: EU Member State 

• Sourcing: Private forest owners with all geolocations known. 

• DDS: Yes — referenced an existing DDS after verifying compliance. 

Why This Product is Compliant 

• All parts and materials that make up the furniture have been traced back to their origin with full geolocation data. 

• All components are covered by valid DDS documents. 

• No indication of deforestation or illegality under Article 3 was found. 

• The information was internally consistent and independently verifiable. 

Scenario 3 – Cocoa-Based Confectionery (Fully Compliant) 

This scenario describes a fully EUDR-compliant cocoa-based confectionary product, where both the final product and its individual cocoa-derived ingredients meet the regulation’s due diligence and information requirements. 

Due Diligence on the Final Product 

• Product: Cocoa-based confectionary (HS 1806) — 2,000 kg 

• Action: The operator performed due diligence in line with Article 8 EUDR, including Article 9 information requirements. 

• Outcome: A Due Diligence Statement (DDS) was submitted for the finished product. 

• This means the operator collected all required details — country of production, geolocations, legality checks — and confirmed no deforestation or illegality. 

Component-Level Compliance 

Ingredient 1 – Cocoa Butter (HS 1804) 

• Origin: Several third countries. 

• Source Details: Multiple farms/smallholdings, all geolocations known. 

• DDS Status: No existing DDS was available, so the operator conducted its own due diligence for this ingredient to verify compliance. 

Ingredient 2 – Cocoa Paste (HS 1803) 

• Origin: Several third countries. 

• Source Details: Multiple farms/smallholdings, all geolocations known. 

• DDS Status: The operator referenced an existing DDS for this ingredient, after confirming that due diligence had been done properly by the original operator. 

Why This Product is Compliant 

• All ingredients have full traceability to plot level, with complete geolocation data. 

• Both cocoa butter and cocoa paste are covered by valid DDS entries — one newly created by the operator, the other verified from existing records. 

• There is no indication of deforestation or illegal production under Article 3. 

• Information is internally consistent and independently verifiable. 

Scenario 4 – Plywood (Non-Compliant Due to Missing Geolocations) 

This scenario describes an EUDR non-compliance case for plywood because one component’s geolocation data is missing, which is a mandatory requirement under the regulation. 

Due Diligence on the Final Product 

• Product: Plywood (HS 4412) — 8,500 m³. 

• Action: Due diligence (DD) was conducted in accordance with EUDR. 

• Problem: The DD process revealed that geolocation information for one component (core veneer) is unknown. 

• Outcome: Because Article 9 requires precise plot-level geolocation for all relevant commodities, the product cannot be placed on the EU market. 

Component-Level Assessment 

Face and Back Veneer Sheets 

• Species: Bintangor (Calophyllum spp.) 

• Country of Production: Third country. 

• Source: Multiple concessions, all geolocations known. 

• DDS Status: Covered by an existing DDS that the operator verified as properly executed. 

• Compliant with Article 9 & 10 requirements. 

Core Veneer Sheets 

• Species: Poplar (Populus sp.) 

• Country of Production: Third country. 

• Source: Farm woodlots, geolocations unspecified/unknown. 

• DDS Status: No valid DDS possible because the fundamental geolocation data is missing. 

• Non-compliant — Without plot coordinates, it is impossible to confirm legality or deforestation-free status. 

Why the Final Product is Non-Compliant 

Under the EUDR, compliance is all-or-nothing for composite products. 

• Even if one component meets requirements (Bintangor veneer), the entire product fails if any other component (Poplar veneer) lacks mandatory geolocation data. 

• Missing geolocation prevents a valid risk assessment under Article 10 and means due diligence obligations under Article 8 and 9 are not fulfilled. 

Scenario 5 – Writing Paper (Non-Compliant Due to Missing Geolocation & Species Data) 

This is an EUDR non-compliance scenario for writing paper because two critical pieces of information — species identification for one pulp component and geolocation data for another — are missing. 

Due Diligence on the Final Product 

• Product: Writing paper (HS 4802) — 1,200 tonnes 

• Action: Due diligence (DD) was carried out in accordance with Article 8 EUDR. 

• Problem: Key data required under Article 9 (species and geolocation) is missing for certain pulp components. 

• Outcome: Because compliance must be verified for all components, the product cannot be placed on the EU market. 

Component-Level Assessment 

Short-fibre pulp (Acacia mangium) 

• Species: Known (Acacia mangium) 

• Country of production: Third country 

• Geolocation: Known 

• DDS Status: Existing DDS verified as properly executed. 

• Compliant with Articles 8–11. 

Short-fibre pulp (Mixed tropical hardwoods of unknown species) 

• Species: Unknown — only classified as “mixed tropical hardwoods” without full identification. 

• Country of production: Third country 

• Geolocation: Known 

• DDS Status: No DDS possible because species information is incomplete. 

• Non-compliant — Article 9 requires species identification for all wood products to verify legality and deforestation-free status. 

Long-fibre pulp (Pinus radiata) 

• Species: Known (Pinus radiata) 

• Country of production: Third country 

• Geolocation: Unknown 

• DDS Status: No DDS possible because geolocation is missing. 

• Non-compliant — Without plot coordinates, legality and deforestation-free claims cannot be validated. 

Why the Final Product is Non-Compliant 

• EUDR is “all parts, all compliant” — every component in a composite product must have complete and verifiable species and geolocation data. 

• Here, one component fails due to missing species identification and another due to missing geolocation. 

• These gaps prevent a valid risk assessment (Article 10) and risk mitigation (Article 11) process. 

• Therefore, the entire batch of writing paper cannot be placed on the EU market.

What are the Common Patterns Across Scenarios 

1. Causes of Compliance Failures 

In every non-compliant case, the breakdown was not in the overall due diligence process, but in component-level gaps. Missing geolocation data, unidentified species, or evidence of post–cut-off-date deforestation for even one ingredient was enough to block the entire product. This underscores a critical truth: EUDR compliance is only as strong as your weakest component. 

2. DDS Referencing vs. Fresh Due Diligence 

Many operators leveraged existing Due Diligence Statements (DDS) to cover parts of a product, provided they could verify the original DD was “properly exercised.” This can save time—but it is risky. If an existing DDS is incomplete, outdated, or non-verifiable, it cascades into a compliance failure. A unique insight here is that blind DDS referencing can become a hidden liability—digital verification tools that auto-validate DDS data are now becoming essential. 

3. Supply Chain Complexity & Risk 

The more processors, intermediaries, or sourcing countries involved, the higher the compliance risk. Multi-country composite products require parallel due diligence across each origin point. In short supply chains, risk mitigation is faster and less resource-intensive, but for complex chains, you need component-level traceability architecture—ideally with geo-tagged, time-stamped data integrated into a single dashboard. 

While EUDR guidance talks about “negligible risk” and “supply chain complexity” as abstract concepts, real-world enforcement will hinge on your ability to map, verify, and defend every link in your composite product’s chain. The winners will be those who treat compliance as a live data system, not a one-time paperwork exercise. 

How Technology Can Help 

Closing the Compliance Gaps with Traceability Solutions 

The most common reasons composite products fail EUDR checks—missing geolocation data, unknown species, or unverified DDS—are exactly where technology can create a decisive advantage. Digital traceability platforms provide a single source of truth for all component-level data, ensuring operators can prove deforestation-free and legally sourced status for every ingredient or material. 

Key Capabilities That Solve Real Problems 

• Geo-tagging at Plot Level – By linking every batch to exact farm or forest coordinates, geo-tagging eliminates ambiguity and simplifies proof of origin. This is crucial for meeting Article 9 requirements. 

• Digital DDS Automation – Automatically generates, stores, and references Due Diligence Statements, reducing human error and ensuring consistent, audit-ready records for each product component. 

• Supplier Risk Scoring – Uses historical compliance data, satellite imagery, and regulatory watchlists to flag high-risk suppliers early—so operators can mitigate before goods reach EU markets. 

The TraceX Advantage 

The TraceX EUDR Compliance Platform combines geo-verified traceability, automated DDS workflows, and real-time AI driven risk intelligence into one integrated dashboard. This enables exporters, processors, and FPOs to manage complex supply chains with confidence, avoid costly rejections, and protect EU market access—all while boosting operational efficiency. 

From Complexity to Clarity: Navigating EUDR for Composite Products 

Composite products—made up of multiple commodities and components—are some of the most challenging categories under the EU Deforestation Regulation. These five real-world scenarios reveal a consistent truth: compliance isn’t just about ticking boxes; it’s about having reliable, verifiable data for every part of the product. Whether the obstacle is missing geolocations, unknown species, or incomplete DDS referencing, the risks are avoidable with robust traceability systems. By embracing digital compliance tools like the TraceX EUDR Compliance Platform, operators can turn complexity into clarity, safeguard EU market access, and strengthen supply chain transparency from source to shelf. 

Want to master the EU Deforestation Regulation from every angle?

Explore our expert blogs on: 

EUDR Systems – How to set up end-to-end compliance infrastructure 
HSN Codes – Classifying commodities correctly for EUDR scope 
EU TRACES – Streamlining Due Diligence Statements for seamless EU filings

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