This creates a significant implementation challenge. Many organisations have already started preparing for EUDR but still need to translate regulatory requirements into practical processes, systems, contracts, controls and responsibilities. We help businesses navigate this transition and build a compliance approach that is robust, proportionate and workable in day-to-day operations.
Why EUDR compliance is challenging
At first glance, EUDR compliance may appear to be a documentation exercise. In practice, it requires businesses to make several fundamental decisions about governance, data, accountability and supply chain cooperation. The following areas are likely to determine whether an organisation is truly prepared.
1. Determining the correct role in the supply chain
A company may act as an operator for one product flow, a downstream operator for another and a trader in a different part of the business. Multinational groups, distributors and platform-based business models may fulfil several roles at the same time. Correctly identifying these roles is critical because the applicable due diligence obligations, reporting requirements and record-keeping responsibilities depend on the company’s position in the supply chain.
2. Building governance around warning signals
Businesses must be able to identify, assess, document and escalate concrete indications that products may not be compliant. Such signals may come from suppliers, customers, auditors, NGOs, media reports, whistleblowers or internal controls. Without a formal escalation process, companies may struggle to demonstrate that potential concerns were handled appropriately and within the required timeframe.
3. Creating end-to-end traceability and reliable records
EUDR readiness depends on the ability to connect product data, supplier documentation, geolocation information, due diligence statements, reference numbers and verification numbers. This is not only a compliance issue but also a systems and process challenge. ERP systems, procurement workflows and document retention policies must be aligned so that information remains complete, accurate and retrievable throughout the supply chain.
4. Aligning contracts, responsibilities and liability
EUDR implementation will often require contractual clarity between suppliers, customers, group entities and service providers. Businesses should clarify who submits the due diligence statement, who retains evidence, which identifiers must be exchanged, how information should be updated and how responsibility is allocated if non-compliance is identified after products have entered the market.
5. Managing downstream and group-level obligations
Obtaining information from an upstream supplier is not always sufficient. Downstream operators and traders may still need to retain relevant information, monitor compliance risks and demonstrate that internal governance is effective. In international groups, additional questions arise about which entity submits information, which entity carries regulatory responsibility and how roles are allocated between EU and non-EU entities.
6. Preparing for the EUDR Information System
The EUDR Information System will become a central part of compliance from the end of 2026 for medium-sized and large companies and from mid-2027 for SMEs. Businesses will need to define who has access, who prepares and reviews submissions, how reference and verification numbers are captured and how data quality is controlled. For many companies, this will require close coordination between compliance, IT, procurement and business teams.
Sector-specific complexity
Certain sectors face additional challenges. Cattle, meat, dairy and agricultural value chains may require detailed farm-level traceability and greater visibility of indirect supply chains. E-commerce and marketplace business models must assess cross-border sales, B2C transactions and platform responsibilities. These situations require a tailored approach, with a generic compliance checklist serving only as a starting point.
How we support you
We assist businesses in translating EUDR requirements into a practical compliance framework. This includes mapping product flows and legal roles, assessing readiness gaps, designing due diligence and escalation procedures, reviewing supplier and customer contracts, supporting data and documentation requirements, and helping organisations prepare for the EUDR Information System.
Our approach is pragmatic and multidisciplinary:
- We identify where EUDR applies across products, entities and supply chains.
- We translate legal obligations into clear internal responsibilities and controls.
- We assist in creating auditable documentation and escalation procedures.
- We support supplier engagement, contract alignment and information-sharing protocols.
- We help management understand the key risks, decisions and implementation priorities.
EUDR compliance is not only about avoiding regulatory risk. It is also an opportunity to strengthen supply chain transparency, improve data governance and demonstrate responsible market access. Organisations that act early can reduce disruption, avoid last-minute remediation and build a more resilient compliance model.
Would you like to understand what EUDR means for your organisation?
Our Sustainable Tax team can help you assess your exposure, identify the most important gaps and develop a practical roadmap towards compliance.
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