The EU Deforestation Regulation (EUDR) has created a wave of questions from companies in the food and beverage sector working to understand their compliance obligations. Following the one-year delay that moved implementation to December 30, 2026 for large enterprises, brands are now entering a crucial time to address these complexities – but with many pressing questions still remaining.
In collaboration with TrusTrace, we have put together this blog series that answers the most common questions that we receive from the field regarding EUDR. This is part 2, so head over to the TrusTrace blog to read part 1 if you haven’t done so already. If you prefer a webinar format, you can watch this webinar co-hosted by our teams that answered the most common concerns from enterprise brands.
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Q: Can we use a single due diligence statement (DSS) for multiple shipments?
A: Yes—and this is an important simplification many companies are overlooking.
“You can cover the shipments of 12 months in one DDS, which is very interesting,” Natalia Yerashevich, Head of Transparency & Supply Chain explains. “Which still is a lot of work because you need to ensure traceability and provide the geolocation coordinates of all the plots of land from which the commodities are coming in all the shipments that will be entering the European Union during 12 months.”
The caveat: “Be careful not to exceed the volumes that you are declaring in the DDS.” This flexibility helps manage administrative burden but doesn’t reduce the fundamental traceability requirements. You still need complete geolocation data for all plots; you’re just consolidating the reporting.
Q: What relief is available for SMEs?
A: Small and medium enterprises have lighter requirements and a later application date:
- Extended deadline: June 30, 2027 (six months after large companies)
- Simplified obligations: Micro and small companies, or natural persons qualifying as primary producers, established in low-risk countries placing relevant products on the market or exporting them, which they themselves produce in that country (i.e. EU producers) will face considerably lighter requirements, i.e. no formal due diligence statement, just a one-off simplified declaration. Geolocation coordinates of the plots of land can be omitted, instead the address of the plot of land or an establishment can be provided.
SME operators do not have the annual reporting obligations of their due diligence system and can delegate the submission of DDS to the next operator in the supply chain, while still retaining the responsibility for compliance. Another simplification that was introduced is that first downstream operators and traders that are SMEs do not have to register in the information system.
Q: How do we handle palm oil derivatives—there are hundreds of them?
A: Palm oil presents a unique complexity due to its extensive derivative tree. A single palm oil import can transform into dozens of ingredients, many remaining in EUDR scope.
Natalia provides guidance: “A company importing palm oil into the European Union is the operator with due diligence obligations, including geolocation requirements. The company transforming this palm oil into fatty acid, which is also part of Annex 1, and placing this fatty acid on the market, becomes the first downstream operator with much lighter obligations: you will only need to collect a due diligence reference number from the operator”
The key: Understanding what you’re placing on the market at your specific stage determines your obligations.
- If you’re importing crude palm oil: You’re an operator with full obligations .
- If you’re buying already-imported stearic acid with existing DDS (first downstream operator): You have lighter obligations. First downstream operators or traders should register in the information system and continue to ensure full traceability by collecting reference numbers of due diligence statements and declaration identifiers assigned to micro and small producers. Further downstream operators or traders do not have to perform this duty any more.
- If you’re using that stearic acid in a final product not in Annex 1: You have no EUDR obligations (but earlier stages still do).
Q: What if our supply chain includes ingredients from both high-risk and low-risk countries?
A: You’ll need to manage different risk profiles within the same product portfolio. This is where a risk-based approach becomes essential.
Natalia recommends: “Prioritise those countries and the volumes, the biggest volumes that you’re sourcing from high and standard-risk countries”.
Your implementation should:
- Address high-risk, high-volume sources first
- Build systems that can scale to cover all sources
- Use the extended timeline to methodically work through each risk category
- Invest in technology that can handle varying risk assessment requirements
Q: Do we need to trace back through every intermediary, or can we go directly to origin?
A: You need good supply chain visibility, but how you achieve it can vary. The regulation requires you to know all plots of land where relevant commodities originated—but it doesn’t mandate you to know all the intermediaries and doesn’t prescribe a specific pathway to get that information. While it is not necessary to know all the intermediaries, it is important to ensure that there is a low risk of mixing with other commodities across all the steps of the supply chain.
Best practice approach:
- Work with direct suppliers to establish data flows
- Build chain-of-custody documentation through each transformation
- Validate data quality and completeness
- Ensure volume balance across the supply chain
As Pauline God, Policy and Partnership Manager at TrusTrace, emphasises: “Look at your data structure and the systems. Are they ready to connect and exchange information across platforms? Because this is also a really key thing, the interoperability between systems.”
Q: What happens if we discover non-compliance after placing products on the market?
A: If you discover or receive information that products are non-compliant after placement, you must:
- Immediately inform competent authorities
- Inform other actors in your supply chain
- Take corrective action
- Document the issue and your response
This obligation applies to both operators and downstream operators. The key is having systems in place to detect issues and respond quickly.
Q: We’re not ready—where should we start?
A: Pauline outlines the no-regret actions: “Map your products—what are the commodities in scope? Who are your suppliers? Start gathering geolocation data from suppliers and make sure the right teams are in place. Look at your data structure and systems, are they ready to connect and exchange information across platforms? Start testing these processes, set up monitoring for deforestation and pilot your due diligence workflows.”
Pauline recommends a phased approach:
- Phase 1: Map products to HS Codes in Annex 1, identify suppliers, assess risk exposure
- Phase 2: Gather geolocation data, review data infrastructure, select technology solutions, build your team
- Phase 3: Pilot processes, test DDS generation, refine based on learning
- Phase 4: Scale to enterprise-wide rollout, educate stakeholders, complete final integration
The December 2026 deadline may seem distant, but as Pauline notes: “Supply chain transformation takes time. The complexity isn’t in understanding the regulation, it’s in orchestrating data collection across fragmented global supply chains involving thousands of smallholder farmers.”
Q: What could be anticipated in the review happening by April 2026?
Further changes could be introduced. We recommend you to monitor the developments yourself or with the support of a public affairs agency like Ohana to have all the information for timely compliance.
If you missed Part 1 of this blog series with answers to questions about mass balance, commodities in scope and operator roles, click below to catch up.
Getting the Support You Need
These questions represent just a fraction of the complexity that food and beverage companies face when it comes to EUDR compliance. The good news? You don’t have to navigate this alone.
For deeper guidance on implementation strategies, watch the full EUDR webinar hosted by TrusTrace and Ohana. When you’re ready to build your compliance program, TrusTrace offers validated solutions for systematic, scalable EUDR compliance, from supply chain mapping through to DDS generation and EU system integration.
At Ohana Public Affairs, we offer support to companies in EU policy monitoring, influencing and preparation for implementation of the EU laws, so don’t hesitate to get in touch and we’d be happy to help you unpack what is happening in Brussels and how it might affect your organisation.