Attention enterprises doing business with the EU! Regarding the EU Deforestation-Free Regulation (EUDR), many are confused about issues such as "production date marking" and "feed traceability". In this continued series, we clarify the rules through 5 frequently asked questions to help you avoid compliance risks.

Industry surveys and remote sensing data indicate that the peak of deforestation linked to rubber cultivation has passed, and rubber itself is no longer a major driver of large-scale deforestation today. However, the EU is highly dependent on natural rubber imports, with a multi-tiered supply chain structure: "smallholders → collection points → primary processing → centralized factories". Raw material mixing in the midstream often leads to broken traceability, exposing enterprises to EU market access risks associated with "deforestation involvement".

Pursuant to Article 9 of the Regulation, this is key information that enterprises must collect. Its purpose is to verify whether products meet the "deforestation-free" standard, and it applies to both goods directly entering the EU and the raw materials used to produce these goods.
1. Non-bovine products: The production date refers to the harvest date, and the time period refers to the production cycle (e.g., the "time period" for timber is the duration of logging operations). Both pieces of information must be linked to specific land parcels. If precise recording is truly impossible, "crop year" or "harvest season" can be used as alternatives.
2. Bovine products: The time period covers the entire life cycle of the cattle, from birth to immediately before slaughter.
- Live cattle (HS codes 0102 21, 0102 29) entering the EU for the first time (e.g., importation, first sale after birth within the EU): A Due Diligence Statement (DDS) must be attached, and all geolocation information related to the first entry must be submitted.
- Subsequent entry of live cattle into the EU: Non-SME traders must supplement "geolocation information of new storage facilities added after the first entry"; SMEs are not required to supplement information or resubmit DDS, but must retain product marketing information for at least 5 years in accordance with regulations.
Exception: Cattle born before June 29, 2023 (prior to the Regulation’s entry into force) and their derivative products are exempt from EUDR.

No! Cattle may be transferred to multiple locations before slaughter. Therefore, enterprises (or non-SME traders) must provide geolocation information for all relevant premises (reflected in the DDS), including: birthplace, breeding farm, grazing area, and slaughterhouse (if the cattle were housed there).
Sounds daunting? Fortunately, there are simplified requirements: instead of providing polygonal boundaries for each premise, only a single latitude and longitude coordinate is required.

The core principle is to "ensure deforestation-free feed", but geolocation information for the feed itself is not required. The specific rules are divided into 3 points:
- When enterprises sell (or export) cattle-related products, they must incorporate "deforestation-free feed" into their due diligence system (based on Preamble 39 of the Regulation).
- A DDS for feed is only required if the feed itself falls under EUDR’s scope of supervision (e.g., soybean meal under HS 1208 10) and is to be placed on the market or exported in the enterprise’s own name.
- If upstream suppliers have already verified feed compliance, enterprises can use invoices, compliance statement numbers, and other documents to prove feed eligibility when inspecting cattle products. In the event of an investigation by competent authorities, these documents may be requested, and they must cover the entire life cycle of the animal (up to 5 years).

Stop immediately!
If an enterprise (or trader) fails to obtain the information required by the Regulation from its suppliers, it must not place the relevant products on the EU market or export them from the EU. Non-compliance will result in penalties.

Yes! Regardless of a country’s risk level, the requirement for "geolocation traceability" is uniform.
Furthermore, enterprises must conduct additional assessments of 3 types of risks:
- The complexity of the supply chain;
- Potential EUDR circumvention attempts;
- The risk of products being mixed with "unknown-source" or "high-risk country/region products" (based on Article 13 of the EU Regulation).
If any important information indicating potential risks is identified (e.g., non-compliant products, circumvention attempts), enterprises must fulfill all obligations in accordance with Articles 10 and 11 of the Regulation and immediately report the information to the competent authorities.

EUDR compliance is interconnected. No details—whether date recording, cattle product traceability, or feed verification—can be overlooked. It is recommended that enterprises proactively review their supply chains and ensure complete information collection at every link to avoid export disruptions due to missing details.

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.