EU Deforestation Regulation (EUDR): what is changing in retail

The EU Deforestation Regulation (EUDR) requires companies to demonstrate that certain products sold in the EU (or exported from Member States) do not originate from deforested or degraded land. For retailers and suppliers, the challenge is ensuring that key information is complete, consistent, and available on time.

What the EUDR is and what it means for your operations

The EUDR (Regulation (EU) 2023/1115) aims to reduce deforestation and forest degradation associated with supply chains. In practice, it requires supporting data to be available before products are placed or made available on the EU market, making it possible to provide evidence of due diligence: collecting, verifying, and retaining the necessary information on the product's origin and its traceability.

The EUDR's critical challenge: decentralized information

Failures often stem from information friction: references that do not arrive, do not match the shipment, or are handled manually. This triggers internal reviews and increases the risk of a hold if the link between the product and the evidence cannot be reconstructed.

If the evidence is missing or does not match the shipment, this results in internal holds and conservative decisions that prevent the product from being released, causing delays across the distribution chain.

Some of the most common problems:

• Role identification (who is responsible and when).
• References that arrive late or without context.
• Mismatches between the reference and the batch/delivery/shipment.
• Duplicates: the same data in multiple locations, with different versions.
• Audit: retrieving the data trail without relying on emails or attachments.

Ultimately, the operational risk.

Products covered by the EUDR

Relevant commodities and products in retail

The EUDR applies to relevant products (Annex I) made from relevant commodities, both in customs operations and on the internal market. Its scope focuses on seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya, and wood, and their derivatives listed in Annex I. The task is to identify which product references fall within scope and ensure traceable data for “EUDR deforestation-free products” across purchasing, shipping, receiving, and placement on the market.

Product checklist: requirements and preparation

• For cattle, the key is to ensure that the identifier is linked to the delivery from goods receipt onward and can be consulted later without going back to the supplier for clarification.
• For cocoa, the critical point is usually the receiving dock: if the data does not arrive with the shipment or cannot be matched to the delivery note, a manual review is required before the goods can be released.
• For coffee, friction arises when there are multiple deliveries or batches: if there is no clear link between the goods received and the identifier, traceability breaks down just when it is needed to validate placement on the market.
• For oil palm, the priority is to ensure that the information is available before the product is placed on the market and recorded in the internal workflow (quality/compliance), without relying on emails or attachments.
• For rubber, the problem is usually consistency: if every supplier sends the data “in their own way,” the retailer ends up normalizing it manually and carrying out additional checks.
• For soya, it is advisable to ensure that the data accompanies the flow from goods receipt to the internal record, as this is where delays due to cross-checks tend to arise.
• For wood, the key is to be able to reconstruct the trail from the goods receipt documentation and the internal record, without later searches or requests to resend documents.

Map of roles and responsibilities

Roles: upstream operator / downstream operator / trader

To understand the EUDR obligations without getting lost in the details, it helps to view the chain in terms of three operational roles:

• Upstream operator: the party that first places the relevant product on the EU market.
• Downstream operator: processes or moves the product at subsequent stages.
• Trader: buys/sells and distributes the product within the EU.

The revision agreed in late 2025 places the burden on the upstream operator: responsibility for submitting the due diligence statement lies with the party that first places the product on the market.

DDR and DDV

When the operator registers its due diligence statement in the EUDR Information System, the system returns two identifiers that link the product (or batch/shipment) to that statement:

• DDR (Due Diligence Reference): uniquely identifies the registered statement.
• DDV (Due Diligence Verification): verification code associated with that statement.

In practice, DDR and DDV are the identifiers that make it possible to link the product/shipment to the statement and maintain that link in internal systems. According to the simplified “map,” these codes may be required by actors further down the chain when they receive goods from a supplier acting as an operator and must retain the associated reference.

Current deadlines and preparation timeline

The EU has confirmed a delay of several months in the implementation of the EU Deforestation Regulation (EUDR), giving companies and authorities more time. The application dates are now as follows:

• 30 December 2026: application date for operators and traders (in general).
• 30 June 2027: an additional six months for microenterprises and small operators.

The postponement is linked to the readiness of the IT system; the revised text will be published in the Official Journal of the EU and will enter into force three days later. In practical terms, this additional time allows companies to organize their catalogs, roles, and data, and test the data capture and validation flow.

Are you an affected supplier or retailer?

To reach 2026 without operational holds, the practical focus is on preparing data and the workflow:

• Identify EUDR-covered products in the product catalog
• Agree with suppliers on what data accompanies each shipment and how it is retained.
• Define controls: ensure data is complete, consistent, and traceable before the product is placed on the market.
• Prepare evidence for internal reviews/audits.

How EDICOM addresses this

Updating workflows to include the information in an optional field

In practice, the EUDR introduces a critical requirement: DDR and DDV must be linked to the product (or batch/shipment) and be available when requested during the customs process. If this data is sent by email or in attachments, or handled through manual processes, errors, validation steps, and reviews increase before goods can be released.

EDICOM helps ensure that this information is transmitted in a structured format between the supplier and retailer through EDI transactions, so that the data arrives with the shipment, is consistent, and can be recorded and retained seamlessly. The aim is to reduce manual tasks and ensure that the reference is linked to the correct goods receipt and can be retrieved when needed.

Validation, traceability, and evidence ready for checks

Beyond transmitting the data, it must be usable in operations:

• Validation: detect blank, inconsistent, or incorrectly formatted values before they cause issues.
• Traceability: link DDR/DDV to the shipment and maintain that link over time.
• Evidence: maintain an internal record for reviews and audits, without last-minute efforts to reconstruct the trail.