EUDR: from compliance to the evolution of global supply chains

At the heart of the European Green Deal, Regulation (EU) 2023/1115, known as the EUDR – European Union Deforestation Regulation, represents a watershed moment for companies operating in the European market. Its mission is clear: to break the link between European consumption and deforestation, ensuring that products marketed in the EU do not contribute to the loss of natural ecosystems, the climate crisis, or the violation of laws in producing countries.

The EUDR is not just an environmental regulation, but a new standard for corporate responsibility. It introduces a transformative principle: no product associated with deforestation can be placed on or exported from the European market.

This means that raw materials must not come from land converted after December 31, 2020 (cut-off date) and must be produced in full compliance with local regulations.

The regulation covers seven raw materials that are fundamental to the global economy — wood, cattle, cocoa, coffee, palm oil, rubber, and soy — and products derived from them. Together, these sectors account for over 60% of deforestation linked to European consumption.

With the EPRR, Europe is calling on companies to radically rethink their supply chains, introducing traceability and control tools that can become drivers of transparency, innovation, and trust for stakeholders.

To ensure the effectiveness of the regulation, the EPRR defines specific roles for each economic actor along the value chain:

• Operator (or primary operator)
• This is the entity that, for the first time, places on the EU market or exports a product subject to the regulation. It is responsible for conducting Due Diligence (DDS) and submitting the Due Diligence Declaration (DDD) through the TRACES system, ensuring that the products comply with the “deforestation-free” criteria. In the most recent proposal, micro and small primary operators are exempt from DDS and will be able to complete a simplified declaration.
• Downstream operator
• Introduced in the October 2025 proposal, this figure represents those who place processed or derived products on the market (such as chocolate made from imported cocoa). They are exempt from DDS but must ensure traceability by referring to the IDs of upstream DDS.
• Trader
• This is the person who distributes or makes available products already placed on the market. They must maintain and transmit traceability information, ensuring data continuity throughout the supply chain.The operational heart of the evolution

Due Diligence (DDS) is the key tool that enables companies to guarantee the sustainable origin of their products.

It consists of three phases:

1. Data collection – accurate information on origin, suppliers, and geolocation of plots.
2. Risk assessment – analysis of potential risks of deforestation or non-compliance.
3. Mitigation – corrective actions and independent audits in case of significant risks.

The process concludes with the Due Diligence Declaration (DDD), uploaded to the European information system TRACES, which certifies the product's compliance.ion

The EUDR goes beyond simple compliance. The need to map, track, and verify every point in the supply chain is, in fact, an opportunity for companies to evolve their sustainability profile:

• Increasing business resilience: a fully traceable, low-risk supply chain is inherently more resilient to external shocks, such as climate crises or regulatory changes
• Driving product innovation: due diligence encourages the adoption of ecodesign criteria and the active choice of low-impact materials, consistent with ESG strategy
• Enabling the co-evolution of the supply chain: The process requires a profound co-evolution with suppliers, elevating the relationship to a collaboration based on shared positive impact

The history of the EUDR is marked by clear stages in formal terms, but these have not been as straightforward in their implementation. After the publication of Regulation (EU) 2023/1115 on May 31, 2023, and its entry into force on June 29, 2023, a preparation phase began that was supposed to allow European companies and institutions to build robust traceability and data management systems.

The legislation provided that Due Diligence (DDS) obligations would become operational from December 30, 2025 for medium and large enterprises, and subsequently, from June 30, 2026, also for micro and small enterprises, giving them more time to adapt to the new requirements and processes of the European information system (TRACES).

However, the timeframe proved to be more complex than expected. The new amendment proposal presented by the European Commission on October 21, 2025 (COM(2025)652)—which introduces operational simplifications and new categories of operators—has generated further uncertainty about the actual date of application.

The proposal includes:

• a new category of downstream operators, exempt from DDS but with traceability requirements via upstream DDS IDs;
• micro and small primary operators exempt from DDS, with simplified declaration in the information system;
• EU producers using intermediate goods (e.g., cocoa → chocolate) authorized to reuse importers' DDS.

This proposal is not yet law: it must be approved by the Council of the EU and the European Parliament and may undergo changes before its implementation.

Do you want to understand the EUDR strategically? NATIVA can support you every step of the way: from compliance to the integration of the regulation to transform your supply chain to product evolution, including through eco-design solutions.

Fill out the form for a free initial assessment of your EUDR readiness level: you will then be contacted by a NATIVA expert and receive a preliminary snapshot of the risks and initial operational recommendations. We will be happy to accompany you on this journey of evolution.

Or write to info@nativalab.com to get to know us and learn more about the NATIVA method.