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Quick summary: Uncertain about navigating the EUDR's complexities? This guide equips Operators & Traders with the knowledge and tools to ensure compliance and build a sustainable supply chain. Discover how traceability solutions can empower your business to thrive under the new EU Deforestation Regulation.
EUDR Requirements for Operators and Traders outline the essential compliance steps businesses must follow under the EU Deforestation Regulation. Operators that place products on the EU market must submit full Due Diligence Statements (DDS) with geolocation data and ensure deforestation-free sourcing. Traders, meanwhile, must maintain traceability and pass on supplier documentation, though with simplified reporting obligations. The October 2025 proposal introduces new categories like downstream operators and micro and small primary operators, refining responsibilities and easing administrative load. Understanding EUDR Requirements for Operators and Traders is critical for building transparent, compliant, and sustainable supply chains by 2025 and beyond.
The EU’s October 2025 proposal (COM(2025) 652 final) marks a pivotal moment in the evolution of the EU Deforestation Regulation (EUDR), balancing environmental integrity with business practicality. The proposal’s goal is to simplify compliance and reduce administrative strain without delaying enforcement, ensuring that sustainability obligations remain enforceable for all actors in global supply chains.
This update directly impacts operators, traders, and the newly introduced categories of downstream operators and micro & small primary operators, each now defined with specific roles and streamlined obligations. For businesses, the message is clear: EUDR compliance is no longer a choice; it’s a strategic necessity. Companies that digitize early, strengthen traceability, and align with the new requirements will not only remain compliant but also build stronger, more transparent, and resilient value chains.
Key Takeaways
The EU Deforestation Regulation (EUDR) is a landmark sustainability policy designed to eliminate deforestation-linked products from the European market. It applies to high-risk commodities such as coffee, cocoa, soy, palm oil, rubber, and timber, as well as their derived products, ensuring they are deforestation-free, legally produced, and traceable to their origin.
At its heart, the EUDR promotes transparency and accountability across global supply chains, placing responsibility on all actors from producers to retailers to prove that their sourcing does not contribute to forest degradation.
EUDR compliance means every shipment of covered commodities entering or leaving the EU must:
This ensures that sustainability claims are backed by verifiable evidence, not just certifications.
Before placing products on the EU market, businesses must submit a Due Diligence Statement (DDS) via the EU’s central information system. The DDS includes:
The inclusion of downstream operators reflects a strategic shift; compliance is now a shared obligation across the supply chain, not just for producers and importers. This alignment ensures that every participant plays a role in maintaining transparency from farm to final product.
In short, the EUDR framework establishes a new global standard for responsible sourcing, one that merges data, traceability, and sustainability to protect forests while enabling ethical trade.
Ready to Stay Ahead of EUDR Compliance?
Explore our expert blogs to understand how to navigate evolving regulations:
[What is EUDR Due Diligence?] – Understand the core obligations and how to get started
[Your Guide to EUDR Compliance] – Step-by-step insights for operators and traders
The European Commission’s October 2025 proposal (COM(2025) 652 final) introduces several targeted amendments to the EU Deforestation Regulation (EUDR), designed to make compliance more practical while maintaining its environmental ambition and enforcement timeline. Here’s what businesses need to know:
The proposal confirms that large and medium-sized operators must still comply by December 30, 2025, as initially planned. The six-month grace period for enforcement until June 30, 2026, remains in effect, allowing businesses time to demonstrate compliance readiness without penalties.
There is no postponement for enterprise-scale actors; compliance preparation must start now.
A new category, Downstream Operators, has been formally introduced. This includes manufacturers and retailers using products already covered by a Due Diligence Statement (DDS). While these businesses are exempt from filing a new DDS, they must register in the EUDR information system and maintain traceability by passing reference identifiers and supplier data along the chain.
Downstream operators now have simplified reporting obligations, but traceability responsibilities remain mandatory.
The proposal introduces Micro and Small Primary Operators, defined as small producers in low-risk countries who directly grow or export EUDR-regulated commodities (e.g., cocoa, coffee, soy). These operators can submit a one-time simplified declaration instead of full DDS submissions and use postal addresses instead of detailed geolocation data.
Simplified compliance reduces administrative burdens for smallholders while maintaining market access.
The EUDR benchmarking system will continue classifying countries as low, standard, or high risk, determining the level of due diligence required. The new proposal extends the grace period for enforcement to June 30, 2026, ensuring that national authorities and the EU’s IT system can stabilize before full implementation.
Businesses must align sourcing strategies with country risk levels and remain adaptive to reclassifications.
Instead of multiple interim assessments, the first consolidated review of the EUDR will occur by June 30, 2030, allowing sufficient time for the collection of operational data. This change reflects the EU’s intent to create a stable, data-informed evaluation process without overburdening operators.
The EUDR framework is shifting toward long-term sustainability governance, prioritizing stability over frequent revisions.
The October 2025 proposal doesn’t delay the EUDR—it refines it. By clarifying roles, simplifying smallholder participation, and improving data systems, it ensures that compliance becomes practical, inclusive, and digitally driven, not just mandatory.
The EU Deforestation Regulation (EUDR) applies differently depending on a business’s role in the supply chain. Each category operator, trader, downstream operator, and micro/small primary operator carries distinct compliance obligations. Below is a practical breakdown with real-world examples to help illustrate how these requirements play out.
Requirements:
Operators must submit a complete Due Diligence Statement (DDS) before placing products on the EU market. This includes plot-level geolocation data, supplier verification, and evidence of deforestation-free production. They must also retain records for 5 years and integrate data with the EUDR IT system.
Example Scenario:
A Vietnamese coffee exporter shipping beans to Germany must upload geolocation data for each farm lot, verify compliance with local land-use laws, and generate a DDS via the EU system. Any shipment missing this documentation cannot legally enter the EU market.
Requirements:
Traders, acting as intermediaries, are not required to submit a DDS but must maintain and transfer traceability documents provided by the operator. Their role is to ensure information integrity throughout the chain.
Example Scenario:
A Dutch commodity trader sourcing palm oil from Malaysia and selling it to EU manufacturers must maintain the original DDS reference and pass it to the buyer. The trader doesn’t create new documentation but ensures no data is lost between transactions.
Requirements:
Downstream operators, retailers, or manufacturers using commodities already covered by a DDS do not file their own DDS. However, they must register in the EUDR database, store reference identifiers, and ensure traceability across their supply chain.
Example Scenario:
A French chocolate manufacturer using cocoa beans imported by a certified operator doesn’t submit a new DDS. Instead, it must record the DDS identifiers of its suppliers and maintain transparent documentation to prove that the raw materials used are compliant.
Requirements:
Micro and small producers located in low-risk countries can submit a one-time simplified declaration instead of repeated DDS filings. They can use a postal address in place of exact geolocation data.
Example Scenario:
A Ghanaian cocoa cooperative classified as a small primary operator in a low-risk country uploads a one-time declaration stating the postal address of its farms and compliance with deforestation-free production. The cooperative’s buyers use this declaration as proof of compliance within their own EUDR submissions.
The EUDR adopts a tiered responsibility model, ensuring every supply chain participant plays a role in achieving traceable, deforestation-free trade. For larger operators, compliance means digital precision and documentation; for smallholders, it’s about accessibility and inclusion through simplified processes.
Platforms like TraceX unify these diverse workflows, automating DDS creation for exporters, tracking supplier data for traders, and simplifying reporting for smallholders, ensuring full EUDR readiness across the chain.
While the EU Deforestation Regulation (EUDR) establishes a structured framework for sustainable trade, its implementation presents complex challenges, especially for large operators managing diverse, global supply chains. The October 2025 proposal may simplify certain aspects, but the core compliance expectations remain demanding. Below are the major risks businesses must anticipate and address proactively.
EUDR compliance requires traceability to the plot level, meaning data from farmers, cooperatives, traders, and processors must align in a single, verifiable record. For multinational enterprises sourcing from multiple countries and suppliers, data fragmentation is a key risk. Disparate systems, spreadsheets, ERP platforms, or offline records make integration challenging.
Risk: Incomplete or inconsistent data could invalidate DDS submissions or delay market access.
Use a centralized digital traceability platform (from TraceX) that automates data collection, validation, and geolocation mapping across all supply chain tiers.
The EUDR information system, built on the EU’s TRACES platform, is expected to process millions of transactions from global exporters. Early testing showed that batch-level DDS submissions can overload infrastructure, particularly for large company groups with complex product portfolios.
Risk: System slowdowns or data bottlenecks could lead to delayed shipments or incomplete DDS filings.
Mitigation: Operators should prepare automated DDS generation through integrated APIs, reducing manual uploads and system strain during high-volume trading cycles.
EUDR’s benchmarking system classifies countries as low, standard, or high risk based on deforestation and governance indicators. These classifications are subject to periodic review, meaning a low-risk country could be reclassified, instantly changing due diligence requirements for exporters.
Risk: Businesses sourcing from low-risk regions could suddenly face stricter reporting obligations and additional verification costs.
Mitigation: Build flexibility into sourcing strategies and adopt AI-based deforestation monitoring and satellite-backed risk alerts to detect land-use changes in real time.
Each stage of the supply chain from farmer to retailer must maintain a consistent chain of custody with shared documentation and reference identifiers. If suppliers fail to update or pass accurate DDS information, downstream operators risk non-compliance, even without direct fault.
Risk: Breaks in data linkage or outdated DDS identifiers can disrupt traceability chains and trigger compliance investigations.
Mitigation: Ensure that suppliers, traders, and downstream operators use synchronized digital systems and shared reference identifiers to preserve full visibility.
Post-grace period, enforcement agencies will begin imposing fines of up to 4% of EU-wide turnover for non-compliance. Beyond financial penalties, non-compliant companies risk market exclusion, brand damage, and loss of ESG credibility.
Risk: Even partial non-compliance (e.g., missing geolocation data or unverified suppliers) could lead to major financial consequences.
Mitigation: Treat EUDR not as a compliance box-tick but as a strategic sustainability mandate. Early digital readiness ensures smoother audits, fewer errors, and greater buyer trust.
See EUDR Compliance in Action
Discover how a Nigerian trading firm streamlined supply chain traceability, supplier onboarding, and DDS submissions using the TraceX EUDR Platform.
The EU Deforestation Regulation (EUDR) demands a new level of transparency and digital precision across global supply chains from farm-level geolocation to due diligence documentation. For many businesses, this has turned into a complex operational challenge. The TraceX EUDR Compliance Platform is purpose-built to make this process simple, automated, and audit-ready, transforming compliance into a strategic advantage rather than a costly obligation.
Here’s how TraceX bridges the compliance gap:
TraceX streamlines the most time-consuming part of EUDR compliance, the Due Diligence Statement (DDS). Through pre-integrated workflows, companies can automatically generate, validate, and submit DDS data directly into the EU’s IT system.
Result: No more manual paperwork, missed declarations, or inconsistent data entries. Every batch, supplier, and shipment is digitally captured and linked to a verified DDS record.
Every transaction and data point on the TraceX platform is backed by blockchain technology, ensuring that once a record is created, it cannot be altered or tampered with. This creates a trust layer that proves the authenticity of your sourcing data and product origin.
Result: Auditors, buyers, and regulators can instantly verify deforestation-free claims, enhancing transparency and compliance confidence.
EUDR compliance extends beyond documentation; it requires continuous monitoring of deforestation risks. TraceX uses AI-powered analytics and satellite imagery to detect changes in land use, forest cover, and crop patterns.
Result: Businesses can receive early alerts on deforestation risks and take corrective actions before they become compliance violations.
TraceX enables seamless digital onboarding of farmers, cooperatives, and processors through mobile and web-based tools. It captures supplier data, farm boundaries, certifications, and geolocations in a unified system.
Result: Faster, verified onboarding and stronger collaboration across supply chain partners, including smallholders in low-risk regions who need simplified compliance support.
With interactive dashboards, TraceX gives businesses real-time visibility into compliance progress, supplier performance, and environmental metrics such as carbon footprint and land-use risk. Reports can be exported instantly for audits or ESG disclosures.
Result: Decision-makers gain data-driven insights that support both regulatory compliance and sustainability reporting goals.
With TraceX, compliance becomes an opportunity, not a burden.
Instead of reacting to regulations, companies can lead with transparency, build stronger buyer trust, and position themselves as sustainability frontrunners in global markets.
The evolving EUDR framework is more than a compliance checklist; it’s a catalyst for building resilient, transparent, and future-ready supply chains. As 2025 deadlines near, operators and traders must shift from reactive reporting to proactive digital compliance, ensuring end-to-end traceability and verified sustainability. With TraceX’s EUDR platform, businesses can automate due diligence, integrate supplier data, and monitor deforestation risks in real time. Those who act now won’t just meet the regulation, they’ll set new benchmarks for responsible sourcing and long-term market leadership.
Navigating EUDR Just Got Easier
Struggling with geo-coordinates, DDS formatting, or TRACES submissions? Explore our latest blogs to decode:
Geolocation Requirements for EUDR Compliance
How to Submit DDS via EU TRACES
The Role of Digital Traceability in Meeting EUDR Standards
To file a Due Diligence Statement (DDS), operators need: farm-level geolocation data (point or polygon), land ownership or legality proofs, crop and harvest records, and risk assessment results. These must be submitted in structured formats like JSON or XML.
Traders typically don’t file DDS unless they become operators. If required, traders must use the EU TRACES portal to submit a DDS, referencing supplier-provided geolocation, documentation, and risk assessments in approved digital formats.
Yes, smallholders must be included if they contribute to the commodity. Platforms like TraceX support onboarding smallholders with GPS mapping, mobile KYC, and offline data collection to ensure full representation and compliance.
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