EUDR in Practice: Who’s in Scope and What to Do

The EU Deforestation Regulation (EUDR) is approaching

The EU Deforestation Regulation (EUDR) applies broadly across supply chains and sectors. The regulation covers seven commodity groups (wood, cattle, coffee, cocoa, soya, oil palm and rubber) and certain derived products.

Use this role-based checklist to understand who is in scope and how to prepare.
Learn how the essentials translate into everyday situations and concrete next steps.

Quick self-check on EUDR

Am I in scope?

Do you place, make available, or export EUDR-covered commodities/ products in the EU?
Are you acting mainly as an operator (placing on the market/ exporting) or a trader (making available)?
What is your company size (micro/ small vs. medium/ large)?

Note:

If you are a large undertaking engaged in trade, you are treated as an operator under the EUDR – follow the Operator checklist.
Some obligations are size-dependent (e.g., annual public reporting for large operator undertakings).

Pick your role below to see what to do next.

EUDR in Practice: Who’s in Scope and What to Do

Operator: what to do

✅ Establish a due-diligence (DD) system
Define and document how you collect required information, assess risk, and mitigate any non-negligible risk. This system underpins your DD-statement.

✅ Collect the required information
Gather supply-chain and product/ batch information (e.g., origin, traceability, supplier declarations, and evidence).

✅ Assess risk and, where needed, mitigate
Perform and document risk assessments; when risk is not negligible, plan and execute mitigation, then re-assess.

✅ File your DD-statement in TRACES and share the reference
Complete the DD-statement in TRACES before imports/ exports/ placing on the market, then pass the statement’s reference number to corporate customers for the relevant batch.

Note: SME operator engaged in further processing
If you are a natural person, micro-, small- or medium-sized operator engaged in further processing, you do not need to prepare a new DD-statement. Obtain the upstream DD-statement reference number, pass it on to your (corporate) buyer, and keep the records.

✅ Keep monitoring and reviewing
Track regulatory updates and national guidance; periodically review your DD system. Large operator undertakings must publish an annual report on their DD system.

Note: Large operator undertakings
Remember the annual DD-system report requirement.

Trader: what to do

Note: Are you a large undertaking engaged in trade?
If you are a large undertaking engaged in trade, EUDR regards you as an operator. Follow the Operator checklist.

✅ Clarify your obligations and size
Confirm whether you are micro/ small or medium/ large and review trader duties accordingly.

✅ Keep and pass DD-statement reference numbers
Obtain and retain the DD-statement reference number for relevant products; pass it forward to corporate customers when required.

Note: SME traders
Natural persons and micro-, small- or medium-sized enterprises engaged in trade (SME traders) do not prepare their own DD-statements. Your duty is to collect, keep and pass DD-statement reference numbers and maintain the required records.

✅ Maintain traceability and records
Maintain supplier and product records and be ready to respond to authority requests.

✅ Stay updated
Monitor regulatory updates and adjust processes as guidance evolves.

Five real-world scenarios

1. Finnish furniture importer (wood products)

Likely an operator. Needs a due-diligence (DD) system, a TRACES DD-statement, and to pass the reference number to corporate customers.
Do this now: Identify your products in scope, map suppliers, pilot one DD-statement.

2. SME grocery wholesaler (coffee & cocoa)

Usually a trader. Keep and pass upstream DD-statement reference numbers; maintain traceability records.
Do this now: Request reference numbers from key suppliers; set up a central log.

3. Medium-sized food manufacturer further processing cocoa

An operator engaged in further processing. No new DD-statement: obtain and pass the upstream reference number; keep records.
Do this now: Update purchase contracts to require timely reference numbers.

4. Large multi-brand retailer (mixed commodities)

A large undertaking engaged in trade → treated as operator.
Do this now: Establish a DD system, plan TRACES submissions, and define your internal “pass-the-ref” process.

5. Micro roastery (coffee)

An operator, but with an extended transition timeline.
Do this now: Start light – supplier map and evidence collection – so you’re not compressing everything against the deadline.

Key dates and scope reminders

Main applicability date: 30 December 2025.
Extended transition for micro- and small-sized enterprises: until 29 June 2026 (note: the extension does not apply to products still covered by EUTR).
The EUDR scope includes wood, cattle, coffee, cocoa, soya, oil palm, rubber, and listed derived products.

Why prepare now?

From customs clearance to reputational risk, companies that have the DD-statement ready, understand their role, and can evidence their process avoid delays and surprises once the EUDR applies. Early preparation improves supply-chain transparency and reduces the risk of non-compliance and last-minute scrambles.

Make EUDR Manageable with EHS Compass

EHS Compass turns EUDR obligations into a manageable, auditable workflow. EHS Compass by Ramboll® brings your requirement registers, monitoring, assessments, and action follow-up into one place so your team can act on what matters.

Regulatory Monitoring: track EU and national updates; push relevant changes straight to your Legal Register and action plan.
Legal Register: centralise EUDR obligations with acknowledgements and review dates – your audit trail in one place.
Assessments: run DD-system and supplier-risk checks with repeatable templates; compare results over time.
Actions & Reminders: assign owners, due dates and follow-ups to close gaps fast.
Dashboards & Reports: show readiness and progress across one or many sites, and export clean reports for management.