Anyone looking into the EU Deforestation Regulation (EUDR) quickly finds explanations of what the law requires. Much less is written about how companies tackle it in practice. In this article we bring together what we learn in our own EUDR projects with Belgian companies: where the work really sits, what works well and where things often go wrong.
Time is running out. Large and medium-sized companies apply the regulation from 30 December 2026, small and micro-enterprises from 30 June 2027. One exception: companies trading timber that already fell under the former EUTR must comply from 30 December 2026, even if they are an SME.
Our three main lessons:
- Scope first which products and suppliers require the most work.
- Start the conversation with your suppliers before requesting data at scale.
- Embed the follow-up in your ERP and appoint someone responsible.
Lesson 1: scope where the work really sits
At the start of a project we often get the same question: do we need to know where every single item was produced? At that point there is usually a list of thousands of item references on the table, and the expectation that each of them requires its own file.
In practice, it is far less daunting, for two reasons. First, many finished products fall outside the scope of the EUDR, even if they contain wood, rubber or cocoa. Second, your obligations depend on your role in the chain. Only the company that first places a product on the European market must submit a due diligence statement. For other products, your role is largely limited to requesting and keeping information.
An example from practice
For one of our SME clients, the scoping looked like this:
- The initial list counted thousands of items.
- Of those, 17 product lines actually fell under the EUDR.
- Only 2 product lines accounted for about 90% of the work.
For those two product lines, the company itself was the first to place the product on the EU market. That is where the heaviest work sits: requesting and validating information, registering the statement in TRACES, and screening the chain thoroughly together with the producing partner.
Map as early as possible which products and suppliers require most of the work. That is where you set your priorities. The rest follows later, and takes considerably less time.
Lesson 2: start the conversation with your suppliers
For products where you act as the operator yourself, the first reflex is often to send an extensive questionnaire to all suppliers. That rarely delivers the desired result. The answers are incomplete because suppliers do not know exactly what you expect, and you lose a lot of time following up and sending reminders.
A more targeted conversation works better. We start with three questions:
- Which certificates are already in place? Existing certificates often already contain much of the information you need.
- Where does your supplier source, and where is production? Here too, certificates sometimes already provide an answer.
- In what form is that information available today? Think of the format, the frequency and the underlying data.
With that short gap analysis you quickly know which information is already available and which questions are genuinely still open. That speeds up the whole project, and avoids overloading your suppliers.
Lesson 3: embed the follow-up in your ERP
Many companies start with a separate Excel file. That works for a few months. Then something changes: a colleague is absent, a new supplier comes on board, or several versions start circulating. At that point the overview is quickly lost.
It is more sustainable to include the EUDR data in the processes that already exist, and therefore in your ERP system, where your purchases and sales are already recorded. We apply three principles:
- Limit yourself to what is needed. Per item, supplier, receipt, invoice line and sales line, record only the data points you really need.
- Build step by step. A complete traceability system is rarely needed at the start. You can expand later, when practice calls for it.
- Distinguish by frequency. Master data on a supplier or product changes little. Shipment-specific data does. Link each type of data to the right follow-up and a clear owner.
Frequently asked questions
Do we need to hire someone for this?
Usually not. It is important, however, that someone internally takes ownership. Without a clear owner, follow-up quickly falls behind in busy periods.
Does every product containing wood, rubber or cocoa fall under the EUDR?
No. Many finished products fall outside the scope, even if they contain one of those raw materials. Printed products, for example, are explicitly excluded. A thorough screening of your item list is therefore the first step.
As a trader, do I also need to submit a due diligence statement?
Not if you are not the first to place the product on the European market. Your role then mainly consists of requesting and keeping information. The heaviest obligations lie with the company that first places the product on the market. Note: if the first company upstream in your chain submits a due diligence statement, you do need to keep the reference number of that statement.
When do I need to be ready?
From the first purchase and sale after 30 December 2026 for large and medium-sized companies, and after 30 June 2027 for small and micro-enterprises. If you trade timber that already fell under the EUTR, 30 December 2026 applies, also for SMEs.
How we help
Together with you, we map which products and suppliers fall under the EUDR and where most of the work sits. We prepare the conversation with your suppliers, and help you build the follow-up into your existing processes. Practical and tailored to your company, without a system that is heavier than necessary.
Want to know where you stand? Get in touch with one of our experts.
Where does your EUDR work really sit?
Together we find where your 90% sits, and build an approach that fits your existing processes.
.svg){kind=logo}
