The Deforestation Regulation covers cattle, cocoa, coffee, palm oil, rubber, soy and wood — and products made from them. It is that last part that surprises people: packaging, pallets, cardboard, furniture, tyres and components fall in well outside the industries that think of themselves as commodity traders. If you are in scope, you have to be able to point to where the raw material was grown or felled, at the coordinates it came from, and submit a due diligence statement before the product is placed on the market.
The burden of proof is yours, even when the supplier is right
That the material genuinely is legal and deforestation-free is not enough. You have to be able to show that you found out, with information that traces back to the origin. A supplier declaration with nothing behind it is not due diligence — it only moves the claim one step back.
Due diligence in three steps
- 1
Collect information
Which product, what quantity, which country and which geolocation. This is where it is decided whether the rest of the process has anything to work with, and where most supply chains show where they are thin.
- 2
Assess the risk
The country's risk classification, the complexity of the chain, whether material is mixed along the way, and how credible the information is. Risk is assessed per consignment, not once for the whole range.
- 3
Mitigate the risk
Additional evidence, audits, sampling or a change of supplier — until the risk is negligible. If it is not, the product may not be placed on the market, and you have to be able to show you made that call.
What the course covers
- Which commodities, products and roles are in scope — and the difference between operator and trader, which decides how much you have to do.
- Geolocation and data quality: which coordinates are required, how they are collected, and what happens when a supplier cannot provide them.
- The due diligence statement and how it is submitted in TRACES.
- Risk assessment in practice, with the criteria applied to real supply chains.
- Contracts and purchasing routines: how the requirement is written in so it can be followed up, rather than becoming a clause nobody reads.
- Checks, penalties and who inside the company carries the responsibility.
Questions about EUDR
- We are not a forestry company. Does EUDR still concern us?
- Possibly. The regulation covers seven commodities and products made from them, and wood is in more products than you first think — packaging, pallets, cardboard and components. An engineering company that exports its products in wooden crates has an EUDR question to answer. The course starts by working out whether you are in scope, because everything else hangs on it.
- Is being FSC or PEFC certified enough?
- No. Certification is strong evidence and makes collection easier, but it does not replace the due diligence the regulation requires — not least because certification does not carry the geolocation EUDR asks for. The course covers how the two relate, so you do not do the same work twice.
- What is the difference between an operator and a trader?
- The operator is whoever first places the product on the EU market or exports it, and that is the role that has to carry out due diligence and submit the statement. A trader sells on within the market and has lighter obligations — but a trader who imports becomes an operator. The role sets the workload, and it is decided by what you do, not by what you call yourself.
- What if a supplier cannot provide coordinates?
- Then the information step one requires is missing, and the risk cannot be assessed as negligible. In practice it becomes a choice between helping the supplier build the data and changing supplier. The course covers how that conversation is held and how the requirement gets into the contract in time.
- Who here should take it?
- Purchasers, sustainability managers, quality and environmental managers, and whoever runs logistics and imports. The statement is submitted by the company, but the evidence comes from purchasing — so that is where the course does most good.
Training in EUDR
An online course at your own pace, for purchasing, quality and sustainability.
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