Meet the EUDR from the origin, with real traceability from the farm.

Seven commodities: cocoa, coffee, rubber, palm oil, soy, wood and cattle, plus certain derivatives listed in Annex I. A product is only in scope if its tariff code appears in that Annex: palm oil margarine or a car's tyres, for example, fall outside it.

The Commission published a package with updated guidance, a revised FAQ and a draft delegated act adjusting Annex I: it adds instant coffee and certain palm derivatives, excludes leather and retreaded tyres, and exempts samples, packaging, waste and second-hand products. It is under public consultation, so it is advisable to check the Annex I in force before operating. It is also confirmed that there will be no further postponement.

Three steps: (1) gather information about the product, its origin and the supply chain, including geolocation; (2) assess the risk that the product comes from deforested land or was produced in breach of the legislation of the country of origin; (3) mitigate that risk where it is not negligible, until you can state with reasonable certainty that the product is compliant. Only then is the DDS submitted. Retexcycle structures all three steps by commodity and by real chain so the team reaches the end of the process with verifiable evidence.

Due diligence is exercised over all the relevant commodities the product contains, not just one. For example, a biscuit made with soy and palm oil requires tracing both chains back to the plot of origin. Each commodity needs its own coordinates, evidence and, where applicable, its own upstream reference DDS.

It depends on your position in the chain. The first party established in the EU that places the product on the market is an operator and exercises full due diligence. The exporter is an operator if it places the product on the market for the first time, or downstream if the product was already in the EU and passed due diligence; in that case it uses a specific TARIC certificate code that exempts it from providing a new reference. Traders and intermediaries keep information about their direct trading partners.

There will be two operators: the one outside and the first party established in the EU that places the product on the market, which becomes an operator under Art. 7 and must exercise due diligence and submit a DDS. This way there is always a responsible party within the EU from whom compliance can be required.

The DDS must be submitted and its reference number obtained before filing the customs declaration, both for imports (release for free circulation) and exports. A single DDS can cover several shipments and be referenced in several declarations. This is where Retexcycle helps: we organise and validate the origin data so your team reaches customs with the evidence ready and no friction.

The operator that imports or exports for the first time, and it is always responsible for ensuring it is correct. Coordinates with at least 6 decimals: polygons for plots larger than 4 ha, a single point for those under 4 ha and for cattle. GeoJSON format, within the technical limits currently in force in the information system. Retexcycle structures the capture by commodity and by real chain so that this data arrives complete and verifiable.

Five years from the placing on the market or the export. This includes the Art. 9 information, the due diligence evidence and the DDS reference numbers, made available to the competent authority upon request.

Each Member State defines them, but the maximum fine for legal persons may not be less than 4% of total EU-wide annual turnover for the previous financial year, must deprive the offender of the economic benefit obtained and increases in the event of repeat offences. Confiscations, temporary exclusion from public procurement and a temporary ban on placing products on the market within the EUDR scope may also be added.