EUDR frequently asked questions

Clear answers to the questions exporters, importers and compliance teams ask us most often about the EU Deforestation Regulation.

What is the EUDR?

The EUDR (Regulation (EU) 2023/1115) is the European Union regulation that prohibits importing or exporting certain raw materials and derived products if they come from land deforested or degraded after 31 December 2020. It covers coffee, cocoa, soy, palm oil, wood, rubber, cattle and their derivatives, and requires verifiable data proving where each batch comes from.

Who does the EUDR affect?

The EUDR affects any company that places, trades or exports coffee, cocoa, soy, palm oil, wood, rubber, cattle or products derived from these commodities to or from the EU, regardless of size. Operators (those placing the product on the EU market for the first time) have the strictest obligations; traders who only distribute already-declared products have more limited ones.

What is a due diligence statement (DDS)?

A DDS is the document an operator submits in the EU's TRACES NT system before placing a product on the European market, declaring that due diligence has been carried out and that the product is deforestation-free. It must include the geolocation of each plot of origin, a risk assessment and the mitigation measures applied.

What geolocation data does the EUDR require?

The EUDR requires the geographic coordinates of every plot where the raw material was produced: a single geolocation point for plots smaller than 4 hectares, and a polygon with the exact boundaries for larger plots. Without this verified geolocation, it is not possible to submit a valid DDS.

What is TRACES NT?

TRACES NT is the European Union's official IT system where operators register and submit their due diligence statements (DDS) before placing a product on the European market. It is the mandatory entry point for EUDR compliance: without a valid DDS in TRACES NT, a product cannot enter or leave the EU.

What is the difference between an operator and a trader under the EUDR?

An operator is whoever places a product on the European market for the first time or exports it from the EU, and must submit a full DDS with geolocation and risk assessment. A trader distributes a product that another operator has already declared, and their obligations are limited to preserving the traceability of that declaration, not generating it from scratch.

What happens if you don't comply with the EUDR?

If you don't comply with the EUDR, your product can be held at the border, suspended from the European market, or rejected outright by your buyer before it even reaches customs. The competent authorities in each country can impose financial penalties and, in serious cases, temporarily ban your company from operating in the EU market.

Are SMEs exempt from the EUDR?

No, SMEs are not exempt from the EUDR, but in some cases they do have simplified obligations, such as micro and small primary operators (MSPOs) established in low-risk countries. These companies can submit a simplified declaration instead of a full DDS, but they still need verifiable origin data.

What is EUDR country risk classification?

Country risk classification is the system the European Commission uses to label each country of origin as low, standard or high risk, based on its deforestation data. This classification determines the level of control customs authorities apply to your shipments: high-risk countries face far more frequent inspections.

What is mass balance and why does it matter for the EUDR?

Mass balance is the principle that guarantees the quantity of raw material declared as deforestation-free entering a process matches the quantity of final product leaving it, through every blend, transformation or change of ownership. Without a verified mass balance, a DDS loses its validity because it becomes impossible to prove the final product genuinely comes from the declared origin.

When does the EUDR come into force?

The EUDR entered into force in 2023, but its effective application has been phased in by company type: first for large operators and traders, then for SMEs, with deadlines the European Commission has adjusted over time. Before each deadline, your company needs its origin-data system already in place, not just starting once it becomes mandatory.

What products and commodities does the EUDR cover?

The EUDR covers seven commodities: coffee, cocoa, soy, palm oil, wood, rubber and cattle, plus an extensive list of derived products such as chocolate, furniture, tyres, leather or paper. If your product contains or is made from any of these commodities, it is likely subject to the EUDR.

What is preserved identity under the EUDR?

Preserved identity is the level of traceability where a batch keeps its individual, identifiable origin throughout the entire process, without mixing with batches from a different origin. It is the most demanding traceability standard, and the one that offers the strongest guarantees under audit, because every unit of product can be linked to a specific plot.

What counts as a plot under the EUDR?

A plot, under the EUDR, is the unit of land where the raw material was produced or harvested, delimited by its exact geographic coordinates. Each plot must be linked to a specific batch in the DDS, and its geolocation is the evidence proving that land has not been deforested after 31 December 2020.

Do I need a polygon or is a geolocation point enough?

It depends on the plot size: if it is smaller than 4 hectares, a single geolocation point is enough; if larger, the EUDR requires a polygon with the plot's exact boundaries. Many supply chains combine both, since they work with smallholders and larger farms at the same time.

What information must a complete DDS include?

A complete DDS must include the operator's identification, the product description and its tariff code, the quantity, the country of production, the geolocation of each plot of origin, and a statement that the risk has been assessed and no significant risk of non-compliance exists. Missing any of these elements invalidates the declaration.

How is it verified that a product is deforestation-free?

It is verified by cross-referencing each declared plot's geolocation with satellite imagery and forest cover databases, to confirm that land has not lost forest after 31 December 2020. The EU's competent authorities carry out these checks systematically, more frequently in countries classified as high risk.

What does the 31 December 2020 cut-off date mean?

31 December 2020 is the deadline set by the EUDR: any product coming from land deforested or degraded after that date cannot enter or leave the European market, regardless of when the product itself was produced or traded. It is the reference every geolocation must clear for a batch to be valid.

What is the difference between deforestation and forest degradation under the EUDR?

Deforestation is the conversion of forest into land for another use, such as farming or livestock. Forest degradation is a structural change to the forest that reduces its capacity to produce goods and services, without eliminating it entirely. The EUDR prohibits products linked to both situations, not only outright deforestation.

Can a cooperative submit a DDS on behalf of its members?

Yes, a cooperative or association can act as an authorised representative and submit declarations on behalf of its members, provided it is established in the EU. It can also submit its own DDS if it places the product on the European market itself, rather than its members doing so individually.

What is a micro or small primary operator (MSPO)?

An MSPO is an operator that meets four conditions: it is a natural person or a micro or small company, it is established in a low-risk country, it places or exports the product directly to the EU market, and it produces the raw material it declares itself. MSPOs can use a simplified declaration instead of a full DDS.

What checks do the competent authorities carry out under the EUDR?

The competent authorities in each country verify that the submitted DDS genuinely matches the physical shipment, check the geolocation against satellite imagery, and can request additional documentation in case of doubt or a complaint. Shipments from high-risk countries face a much higher inspection rate than those from low-risk ones.

How often do you need to submit a DDS?

A DDS must be submitted before each placing on the market or export, although a single declaration can cover several shipments or batches if certain continuity conditions are met. It is not an annual or one-off obligation: it repeats every time a product subject to the EUDR enters or leaves the EU.

Can one DDS cover several shipments or batches at once?

Yes, a single DDS can cover several shipments or batches if they are placed on the market successively over a given period and share the same origin and risk conditions. This reduces the administrative burden for operators with constant flows, as long as each batch keeps its individual traceability down to the plot.

What happens if my supplier doesn't give me geolocation data?

Without verified geolocation for each plot of origin, you cannot submit a valid DDS, so the product gets blocked before reaching the European market. It is one of the most common reasons operators now require their suppliers to use a proper origin-data capture system, instead of relying on spreadsheets or manual forms.

Am I required to share my DDS verification number with my customers?

No, there is no legal obligation to share your DDS verification number with customers or end consumers. You only need to provide it to the competent authorities when requested, or to a direct customer verifying your exercise of due diligence in response to a substantiated concern.

How does the EUDR relate to the Renewable Energy Directive (RED)?

The EUDR and the RED are complementary: both aim to curb deforestation and climate change, and a product subject to the EUDR can also count as renewable energy under the RED if it meets its specific requirements. Low indirect land use change (ILUC) certificates used under the RED can also serve as evidence for the EUDR.

Does the EUDR apply to products already in transit before the application date?

In general, the EUDR applies based on the date the product is placed on or exported from the European market, not on when it was manufactured or shipped. If you have doubts about a specific shipment in transit, it's worth checking with your legal advisor, since transitional rules vary by product type and exact date.

What happens if my country of origin is classified as high risk?

If your country of origin is classified as high risk, your shipments face a much higher inspection rate from customs authorities, and the risk assessment in your DDS must justify in more detail why the specific product is not linked to deforestation. It doesn't stop you from operating, but it demands a stronger level of evidence.

What penalties exist for failing to comply with the EUDR?

Penalties for failing to comply with the EUDR are set by each member state within a common framework, and include financial fines proportional to the environmental damage or the value of the product, confiscation of the goods, and temporary exclusion from public procurement or EU funding programmes in serious or repeat cases.

How Retexcycle solves it

How does Retexcycle help with EUDR compliance?

Retexcycle captures geolocation data directly at the farm with Retexcycle Origins, and keeps it with preserved identity through every collection, blend and transformation up to the final DDS. On the European buyer's side, Retexcycle Compliance Hub centralises your suppliers, assesses their country risk and generates the declaration ready for TRACES NT, without having to reconstruct origin data by hand.

How does Retexcycle capture geolocation data at origin?

Retexcycle Origins collects geolocation directly on the ground, at the moment of collection, instead of reconstructing it later from paperwork. Each plot is linked to its batch from the very first moment, with the corresponding point or polygon depending on its size, ready to feed into the DDS without extra work.

How does Retexcycle preserve batch identity?

Retexcycle tracks each batch through collection, blending and transformation without losing its link to the plot of origin, instead of merging it with batches from a different provenance. So when it's time to declare in TRACES NT, every unit of product still has a specific plot backing it up.

How does Retexcycle generate a DDS ready for TRACES NT?

Retexcycle Compliance Hub brings together geolocation, country risk assessment and traceability for each batch in one place, and generates the declaration in the format and fields TRACES NT requires. This avoids the manual work of pulling together scattered data from different suppliers and documents before every shipment.

Does Retexcycle assess country risk automatically?

Yes, Retexcycle Compliance Hub applies country risk classification directly to your registered suppliers, so you can see at a glance which part of your chain needs more evidence or extra checks. You don't need to look up the classification separately or cross-check it by hand for each supplier.

What is the difference between Retexcycle Origins and Retexcycle Compliance Hub?

Retexcycle Origins is built for exporters and producers: it captures traceability from the farm. Retexcycle Compliance Hub is built for European importers and operators: it receives that origin traceability and turns it into a declaration ready for TRACES NT. Both products connect to each other, so data captured at origin reaches the European buyer without needing to be rebuilt.

Can Retexcycle verify mass balance across blends and transformations?

Yes, Retexcycle tracks the quantity of raw material declared as deforestation-free through every blend and transformation, to confirm that what goes into a process matches what comes out of it. This is what keeps a DDS valid when a batch goes through several stages before reaching the final product.

How long does it take to implement Retexcycle in my supply chain?

Implementation time depends on how many suppliers and plots you need to onboard, but the first pilot batch is usually traced within around 15 days, depending on workload. You also get a one-month trial with Retexcycle Origins to see how it performs with your actual supply chain before deciding.

Does Retexcycle work for commodities other than coffee and cocoa?

Yes, Retexcycle is designed for any of the commodities covered by the EUDR: coffee, cocoa, soy, palm oil, wood, rubber and cattle, as well as biomass certified under RED III/SURE. The geolocation capture and mass balance mechanism is the same, adapted to the specifics of each chain.

Can I try Retexcycle before committing to it?

Yes, you can request a demo using your own origin data, with no commitment, to see how Retexcycle performs with your actual supply chain before deciding. It's the most direct way to check whether the system fits your suppliers and the volume of plots you need to trace.

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