The preparation for compliance with the EU Deforestation-Free Regulation (EUDR) has entered a critical phase. Although the extension proposal provides enterprises with a buffer period, processing and trading enterprises still face a core challenge: how to establish a stable, reliable, cost-controllable, and trade-secret-protective supply chain evidence system within a limited time?
Many enterprises fall into the misunderstanding that "compliance = providing as much data as possible". In fact, EUDR adheres to the "data minimization principle"—only core data necessary for compliance needs to be submitted, not all supply chain information.
Combining the core requirements of the regulation and practical logic, this article popularizes key compliance points to help enterprises avoid misunderstandings and make efficient arrangements.

EUDR does not require enterprises to disclose all supply chain information. Its core is to prove product compliance through "minimum necessary data" by answering three core questions, which are also the key basis for the Due Diligence Statement (DDS):
Has there been deforestation or forest degradation on the raw material production plots since 2020?
Is the use of the plots and product production in line with the legal requirements of the producing country?
Is the processing and trade chain from raw materials to finished products fully traceable?
The core goal of enterprise compliance is to build an evidence chain around these three questions, without proactively disclosing data unrelated to compliance.
Excessive disclosure will not only increase management costs but also may leak trade secrets, violating the requirements of EU data protection, competition law and other relevant regulations.

To achieve "precision compliance + confidential protection", enterprises need to establish a clear EUDR Data Protocol, defining the boundaries of "must submit, not disclose, and need to provide in special cases", which mainly includes four key points:
Mandatory submission data: It shall accurately cover the core of compliance—GPS coordinates of raw material plots, production legality certificates (land ownership, production licenses), key supply chain traceability documents, etc., to ensure direct response to the three core judgment questions and that the data is true and verifiable;
Information use authorization: When transmitting compliance information in the supply chain, it is necessary to clarify the scope of information use, quality requirements and liability for breach of contract, to avoid unauthorized use of information or legal risks caused by data errors;
Non-proactive disclosure of data: There is no need to disclose trade secret-related information to EU customers (operators), such as core production processes, customer lists, cost data, etc.; at the same time, disclosure of personal information (ID card numbers, contact information, etc.) is strictly prohibited to comply with data protection regulations;
Special disclosure scenarios: Supplementary data only needs to be provided when explicitly required by the EU Competent Authority (CA), and the CA has a legal obligation to keep trade secrets and shall not disclose them to third parties without authorization.

The current compliance buffer period is a critical stage for enterprises to establish data protocols, with the core goal of "low cost, auditable, and confidential", which can be promoted in three steps:
Clarify data boundaries: Refer to EUDR regulations, EU implementation guidelines and regulatory law enforcement logic, sort out the "list of data necessary for compliance", eliminate irrelevant information, and avoid redundant collection;
Build internal evidence chain: Establish a complete internal data system independently, including raw material source records, production process documents, compliance certificates, etc., to ensure information closed-loop and self-prove compliance without relying on external disclosure;
Optimize information transmission methods: Provide only "compliance summary information" (instead of original documents) to EU customers, which not only meets the DDS declaration requirements but also minimizes the risk of trade secret leakage, in line with the concept of "zero-knowledge proof".

Misunderstanding 1: The more data, the more compliant? Wrong. Redundant data not only increases management costs but also may violate data protection regulations or leak trade secrets. It is sufficient to focus on the data required for the "three core questions";
Misunderstanding 2: All information must be provided to customers? No. Only the summary information necessary for compliance needs to be transmitted, and trade secrets, personal information, etc., shall not be proactively disclosed;
Misunderstanding 3: No need to formulate clear protocols? Extremely risky. Lack of data protocols may easily lead to "failure to submit what should be submitted and disclosure of what should not be disclosed", resulting in compliance penalties or commercial losses;
Misunderstanding 4: Must provide all data requested by the competent authority? No. Only relevant data required by the CA shall be provided, and trade secrets can be claimed. The CA has a confidentiality obligation.

The core of EUDR compliance is "precise data + standardized protocols". Enterprises advancing independently are prone to problems such as "unclear data boundaries, no idea for protocol construction, and no method for confidential protection".
Based on in-depth interpretation of EUDR regulations and relevant EU systems, combined with industry practical experience, SKYCO2 provides targeted compliance support:
Assist in sorting out the "list of data necessary for compliance", clarify data collection boundaries, and avoid redundancy and omissions;
Guide the construction of data protocol framework, standardize information authorization, transmission and confidentiality processes, and balance compliance and trade secret protection;
Provide compliance information collation templates to help enterprises generate "compliance summaries" and reduce information transmission risks;
Real-time tracking of EUDR policy and regulatory dynamics, synchronizing rule adjustments and optimizing compliance plans.
If your enterprise is worried about "which data to collect, how to protect trade secrets, and how to build a compliance system", please feel free to contact SKYCO2 (Qinggong Internet).
We will use practical services to help you establish a low-cost and highly reliable EUDR compliance evidence system, and while safeguarding trade secrets, calmly respond to regulatory challenges and firmly seize EU green trade opportunities.