EUDR Compliance for Food Commodities

The EU Deforestation Regulation (EUDR) is the most significant change to EU commodity import rules in a decade. If you trade cocoa, coffee, soy, palm oil, rubber, wood, or cattle products - or any product derived from these commodities - you need to understand your obligations before the enforcement dates hit.

This guide explains what the EUDR requires, which food commodities are affected, the timeline for compliance, and the practical steps traders need to take.

What Is the EUDR?

Regulation (EU) 2023/1115 - the EU Deforestation Regulation - was published in the Official Journal of the European Union on 9 June 2023 and entered into force on 29 June 2023. It replaces the earlier EU Timber Regulation (EUTR) and dramatically expands the scope of deforestation-related trade rules.

The regulation's core requirement is simple: any relevant commodity or derived product placed on the EU market or exported from it must be deforestation-free. Specifically, the products must have been produced on land that was not subject to deforestation after 31 December 2020.

In addition to deforestation-free status, the products must have been produced in accordance with the relevant legislation of the country of production - including land use rights, environmental protection, labour laws, tax obligations, and human rights requirements (including free, prior, and informed consent of indigenous peoples).

Which Commodities Are Covered?

The EUDR covers seven core commodities and their derived products:

Commodity	Examples of Derived Products	Relevance to Food Traders
Cocoa	Chocolate, cocoa butter, cocoa powder, cocoa paste	High - chocolate-coated nuts, cocoa-based snacks
Coffee	Roasted coffee, instant coffee, coffee extracts	High - direct commodity trade
Oil palm	Palm oil, palm kernel oil, palm olein, glycerol	High - used in many processed food products, frying oils, margarine
Soy	Soybeans, soy flour, soy oil, soy lecithin, soy protein	Medium - soy lecithin as emulsifier, soy oil in processing
Rubber	Natural rubber, latex, tyres, conveyor belts	Low - packaging materials only
Wood	Timber, paper, cardboard, printed matter, charcoal, furniture	Medium - cardboard packaging, paper labels, wooden pallets
Cattle	Beef, leather, tallow, gelatine	Low - gelatine in some confectionery

Due Diligence Requirements

The heart of the EUDR is the due diligence system that operators and traders must implement. This consists of three steps:

1. Information collection

For each relevant product, you must collect:

• Geolocation data - The GPS coordinates (latitude/longitude) of all plots of land where the commodity was produced. For plots larger than 4 hectares, a polygon (set of coordinates defining the boundary) is required.
• Description and quantity of the product, including HS/CN code.
• Country and region of production.
• Supplier identity - Name, address, and registration details of all operators in the supply chain.
• Verification of legality - Adequately conclusive and verifiable information that the product complies with the legislation of the country of production.

2. Risk assessment

Based on the collected information, you must assess the risk that the products are non-compliant. The risk assessment must consider:

• The country benchmarking classification (see below).
• Prevalence of deforestation or forest degradation in the production area.
• Concerns about the country of production's governance and enforcement.
• Complexity of the supply chain and risk of mixing compliant and non-compliant product.
• Any RASFF or validated concerns about the commodity from that origin.

3. Risk mitigation

If the risk assessment identifies a non-negligible risk, you must take adequate risk mitigation measures to reduce it. This can include:

• Requesting additional data or documentation from suppliers.
• Independent third-party audits or verification.
• Satellite imagery analysis to confirm no deforestation occurred.
• Laboratory testing (e.g., isotope analysis to verify origin).

Only when the risk is reduced to negligible can the product be placed on the EU market. The due diligence statement must be submitted to the EU Information System (a centralized digital platform) before the product is placed on the market.

EUDR Timeline and Milestones

Date	Milestone	Who Is Affected
29 Jun 2023	Regulation enters into force	All operators and traders
31 Dec 2020	Cut-off date: land must not have been deforested after this date	All supply chains
Oct 2024	European Commission proposes 12-month delay to application dates	All operators and traders
30 Dec 2025	Application date for large operators and traders (non-SMEs)	Large companies
30 Jun 2026	Application date for SMEs (micro, small, and medium enterprises)	SMEs
30 Jun 2025	Expected publication of country benchmarking classifications	All - determines inspection frequency
Ongoing	EU Information System operational for due diligence statements	All operators placing products on the EU market

Country Benchmarking System

The European Commission will classify countries (or parts of countries) into three risk categories:

• Low risk - Simplified due diligence permitted. Operators only need to collect information and submit due diligence statements. Physical check frequency by authorities: 1%.
• Standard risk - Full due diligence required. Physical check frequency: 3%.
• High risk - Enhanced due diligence required, plus additional scrutiny from EU authorities. Physical check frequency: 9%.

The benchmarking assessment is based on deforestation rates, forest cover, commodity production trends, and governance indicators. Countries can be reclassified as data evolves. The official benchmarking list was expected by 30 December 2024 but has been delayed alongside the broader implementation timeline.

Penalties for Non-Compliance

The EUDR requires Member States to establish penalties that are effective, proportionate, and dissuasive. The regulation sets minimum standards:

• Fines of at least 4% of the operator's total annual EU-wide turnover.
• Confiscation of the relevant products and of any revenue earned from them.
• Exclusion from public procurement processes.
• Temporary prohibition from placing relevant products on the EU market or exporting them.

For serious or repeated violations, Member States may impose even stricter penalties. Given the potential for fines based on total EU turnover (not just turnover from the non-compliant product), the financial risk is substantial.

How the EUDR Affects Nut and Dried Fruit Traders

For traders dealing exclusively in pure tree nuts, dried fruits, and seeds, the direct impact of the EUDR is limited. However, several indirect impacts require attention:

Chocolate-coated and flavoured products

If you trade chocolate-coated almonds, cocoa-dusted cashews, or any product containing cocoa, the cocoa component must be EUDR-compliant with full traceability to deforestation-free plots.

Palm oil in processing

Many roasted, flavoured, or fried nut products use palm oil. If your product contains palm oil or palm oil derivatives, EUDR compliance is required for that ingredient.

Packaging materials

Cardboard boxes, paper labels, and wooden pallets contain wood-derived materials. While the European Commission has indicated that packaging may receive simplified treatment, the regulation technically covers all derived products. Monitor guidance updates from the Commission closely.

Supply chain documentation

Even if your core product is out of scope, European buyers are increasingly requesting EUDR-related documentation as part of broader ESG (Environmental, Social, and Governance) requirements. Being prepared with forest-risk assessments and traceability data positions you competitively.

What Corsodoro Does to Ensure Compliance

Corsodoro is proactively preparing for full EUDR compliance across all relevant product lines:

• Supply chain mapping - We maintain geolocation data for all origin-level suppliers, including GPS coordinates of production areas for relevant commodities.
• Ingredient traceability - For products containing cocoa, palm oil, or soy derivatives, we require full upstream traceability from our ingredient suppliers.
• Third-party verification - We work with independent verification bodies to confirm deforestation-free status using satellite imagery analysis.
• Digital documentation - All due diligence statements and supporting evidence are maintained on our trade platform, accessible to buyers for audit purposes.
• Ongoing monitoring - We track regulatory updates from the European Commission and adjust our compliance programme accordingly.

Practical Steps for Traders

1. Identify which of your products are in scope - Review your product catalogue for any items containing cocoa, palm oil, soy, rubber, wood, coffee, or cattle derivatives.
2. Map your supply chain - For in-scope products, identify the origin of each relevant ingredient and collect geolocation data.
3. Engage suppliers early - Communicate EUDR requirements to your suppliers and request the necessary data. Suppliers who cannot provide geolocation data may need to be replaced.
4. Register in the EU Information System - Ensure your company is registered and ready to submit due diligence statements before the application date.
5. Conduct risk assessments - Use the country benchmarking system (when published) and your own supply chain data to assess risk levels.
6. Document everything - Keep comprehensive records. Due diligence statements and supporting documentation must be retained for at least 5 years.
7. Monitor regulatory updates - The EUDR is still evolving. Follow guidance from the European Commission, your national competent authority, and industry associations.