EUDR: What information would your EU trading partners expect from you?

Question

If a company (based outside the EU) supplying timber products does not export or place them on the EU market, but supplies customers who do, what would be expected of the company in relation to EUDR? What kind of information would EU trading partners ask for?

Background information

The EU Regulation on Deforestation-free Supply Chain (EUDR, Regulation (EU) 2023/1115) sets out rules to ensure that supply chains for key commodities are free from deforestation and forest degradation after 2020. The seven commodities covered by the EUDR are cattle, cocoa, coffee, oil palm, rubber, soy, and timber and their derived products.

The law requires EU-based companies that make the relevant commodities and products available in the Union or export them from the European market to collect information and carry out risk assessments to assess whether the relevant raw materials have been produced in areas that have been subject to deforestation after 2020.

As a company based outside the EU, what are my obligations when supplying goods to the EU?

There are no legal requirements for non-EU countries and companies to comply with EUDR. The Regulation sets out obligations for operators and traders established in the European Union (see chapter 2 of the EUDR) as well as for the EU member states and their competent authorities (see chapter 3 of the EUDR). Because your business is based outside the EU, you do not have the legal requirements. 

For more details, see Does EUDR apply to companies outside the EU?

Due to the complexity of the supply chain as in your case, many companies outside the EU supply relevant commodities (cattle, cocoa, rubber, timber, oil palm, coffee, soy) and their derived products to EU-based companies. EU-based companies (within the scope of the EUDR) are heavily dependent on their suppliers for access to supply chain information to prove compliance with the EUDR. This includes information that helps companies demonstrate that their products are (1) deforestation-free, (2) produced in accordance with the relevant laws of the country of production, and (3) traceable.

The required information includes, but is not limited to, the following:

  • a description, including the trade name and type of the product, and in the case of wood the common and full scientific name of each species;
  • the quantity of the product;
  • the country of production;
  • the geolocation of all plots of land where the relevant commodities were produced;
  • the date or time range of harvesting or production (period defined by a start date and end date);
  • the name, postal address, and e-mail address of any company or person from whom you received the relevant products;
  • the name, postal address and email address of any business, operator or trader to whom the relevant products have been supplied;
  • the name, postal address, and e-mail address of each business, operator, or trader to whom the relevant products have been supplied;
  • adequately conclusive and verifiable information that the relevant products are deforestation-free;
  • adequately conclusive and verifiable information that the relevant commodities have been produced in accordance with the relevant legislation of the country of production, including any arrangement conferring the right to use the respective area for the purposes of the production of the relevant commodity.

(For more detailed information, see Article 9 EUDR.)

Being able to provide the above information will make your business stand out from the crowd and position you as an ideal trading partner in a regulatory-demanding environment.

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