EUDR deforestation traceability: commodities, geolocation, due diligence statements and the data behind them

EUDR turns origin into mandatory batch-level data

The EU Deforestation Regulation (EU) 2023/1115 makes plot-level origin a legal precondition for placing relevant products on the EU market or exporting them. Products must be deforestation-free, meaning produced on land not deforested after the cut-off date of 31 December 2020, and produced in line with the laws of the country of production. Operators that first place the goods on the market must file a due diligence statement beforehand. The result is a traceability requirement that most product data architectures were never built to carry.

Seven commodities and a long tail of derived products

Scope follows customs codes, so the derived product list matters more than the commodity names. Annex I lists covered products by HS code.

Manufacturers in furniture, packaging, publishing, automotive and food are therefore affected even when they never buy a raw commodity directly. Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, removed cattle hides and leather, certain rubber articles and vehicle seats from Annex I, and adds soluble coffee and further palm oil derivatives from 30 December 2027. Packaging made from paper or wood also falls in scope when placed on the market as a product in its own right, which links EUDR to packaging data model work.

Geolocation and the due diligence statement

The due diligence statement is the central compliance record. It references the product, quantity, country of production and the geolocation of all plots of land where the commodity was produced. Plots above 4 hectares require polygon coordinates, while smaller plots may use a single point; cattle use the establishments where animals were kept. Statements go into the EU information system, which returns a reference number that travels with the goods and appears in customs declarations.

Due diligence itself has three steps: collect information, assess risk and mitigate risk. Country benchmarking classifies countries as low, standard or high risk, and low-risk origin allows simplified due diligence. Operators keep records for 5 years. The 2025 amendment, Regulation (EU) 2025/2650, also simplified obligations downstream: later operators and traders no longer file their own statements, but keep supplier and customer records, including statement reference numbers, and larger ones register in the information system.

Timing as amended: plan for the earlier date

The original application date of 30 December 2024 moved twice. A first amendment postponed it by 12 months to 30 December 2025. Regulation (EU) 2025/2650, published in December 2025, moved application for large and medium operators to 30 December 2026 and for micro and small operators to 30 June 2027, with timber products already under the EU Timber Regulation following the earlier date. The Commission's simplification review of May 2026 proposed no new postponement, and the Commission works towards application on 30 December 2026. Compliance teams should treat that as the planning date and monitor EUR-Lex for the consolidated text.

Where EUDR data lives across PLM, ERP and PIM

EUDR data is transactional at its core, so ERP and supply chain systems own it, with PLM and PIM holding the product-level scope flags.

• PLM: material and component specifications with commodity content, HS codes per component and approved supplier lists; the bill of materials shows which finished goods inherit EUDR scope, as covered in BOM management.
• ERP and procurement: purchase orders with supplier, batch, quantity, country of production, geolocation file references and due diligence statement reference numbers.
• Traceability or geodata platform: plot polygons in GeoJSON, satellite risk checks, supplier declarations and evidence documents.
• PIM: product-level flags such as EUDR in scope, HS code and commodity, plus statement references where customers or marketplaces request them.

The key design decision is mass balance. EUDR does not accept mixing compliant and unknown-origin material in a way that breaks the link to plots, so segregation must be visible in batch data. Where compliant material from many plots is blended, the statement must list the geolocation of every contributing plot, which can mean thousands of coordinates for a single shipment of cocoa or palm oil. Organisations with blended raw materials typically face the largest effort, an estimated 6 to 18 months for supplier onboarding and data capture. Aligning identifiers with the approach in DPP data architecture and GS1 Digital Link avoids building a second traceability stack later.