The EUDR (EU Zero-Deforestation Regulation) has entered the countdown phase. Export enterprises dealing in timber, soybeans, and other regulated commodities must overcome multiple hurdles such as plot marking and supply chain traceability. This issue breaks down five core pain points to help you avoid detours in compliance.
1. Can one polygon cover multiple plots?
Absolutely not!
Polygons are used to outline the boundary scope of commodity production plots. Regardless of whether they are contiguous, each polygon must correspond to a single plot. To put it simply, a polygon is the "electronic boundary map" of a plot—one map per plot, even if multiple plots are adjacent, they must be drawn separately.For example, if you purchase soybeans from 10 plots, 10 sets of polygon data must be attached to the due diligence report.It is particularly important to note that when an area only contains some target plots, you must never enclose them with a single polygon—this would incorrectly include non-target plots.
2. Do I need to provide the perimeter when marking a plot?
No, and it’s not feasible either!
The Regulation does not require providing the perimeter, and in practical operations, accurate positioning cannot be achieved through the perimeter alone.However, for non-livestock plots exceeding 4 hectares, boundaries must be marked with polygons (instead of only providing the central point + area), and there must be sufficient latitude and longitude data points to ensure precise boundaries.
3. Will the EU conduct on-site inspections in third countries?
Yes, but with prerequisites!
EU competent authorities may conduct on-site audits in third countries in accordance with Article 18(2)(e) of the Regulation, but they must obtain the consent and cooperation of the local government.In addition, if a product is determined to be "potentially non-compliant" or "non-compliant", EU member states and competent authorities are not required to conduct consultations with the producing country in accordance with the Regulation.
4. What is supply chain traceability?
In short, it means "5-year documentation retention + three-level verification system + full-process information transmission". Non-small and medium-sized enterprises (SMEs have a grace period) should pay special attention to the following:
● 5-year documentation retention: Geographical data (e.g., plot coordinates), procurement documents, etc., must be retained (see Article 9 and Annex II of the Regulation for details);
● Establish a verification system: Collect information, conduct risk assessments, and implement risk mitigation measures (corresponding to Articles 10-11 of the Regulation);
● Transmit information downstream: Upstream parties provide compliance certificates to downstream parties, and downstream parties cannot shirk their responsibilities—even if upstream parties have completed verification, their own obligations remain unchanged;
● Ensure the accuracy of submissions: Operators and traders of non-SMEs must ensure that the traceability information provided to the law enforcement agencies of member states in the due diligence statements submitted through the information system is accurate and error-free.
● Ensure information system security: The development and operation of the information system will comply with relevant data protection regulations, and security measures will be equipped to ensure that the integrity and confidentiality of shared information are not compromised.
5. How to trace products purchased from multiple countries?
Regardless of the length or complexity of the supply chain, operators and traders of non-SMEs must ensure that the required traceability information provided to the competent authorities of member states is correct.Information is "summarized level by level" along with the goods in the supply chain! For example, if you collect soybeans from 100 plots across 10 countries, the due diligence statement must clearly specify the geolocation information of all 10 producing countries and the specific locations of each plot involved in the transportation of the batch of goods in these countries.
Easily Navigate EUDR Compliance
Faced with the complex rules and tight deadlines of EUDR, many enterprises may feel confused: not sure where to start with due diligence? Unclear how to trace the origin of commodities? Worried that cumbersome compliance processes will affect business progress?Don’t worry! SKYCO2 provides enterprises with end-to-end compliance services for the EU Zero-Deforestation Regulation (EUDR). We help you address all bottlenecks in the compliance process, assist your enterprise in seamlessly meeting EU market access requirements, and enable you to calmly navigate EUDR while firmly seizing market opportunities!If your enterprise intends to prepare for EUDR in advance, please feel free to contact us at any time, and let our professional team develop a tailor-made compliance plan for you.