Understanding the Latest EUDR Updates: Simplification and Implications for Business
As the deadline for EUDR compliance looms just eight months away, large organizations are under pressure to prepare. To help businesses, the EU has published updates to the EUDR FAQ and Guidance documents, along with proposed amendments to Annex I, which outlines the products covered by the regulation. This comes alongside the ESG Omnibus and aligns with its aim to simplify due diligence obligations for companies:
Reusing due diligence statements for reimported goods: Large companies can now reuse existing due diligence statements when goods, previously on the EU market, are reimported. This means businesses don’t have to start from scratch for reimported products, saving time and resources.
Authorized representatives for company groups: An authorized representative can now submit a due diligence statement on behalf of members of company groups. This streamlines the process and reduces the administrative workload for businesses operating as part of a larger corporate structure.
Annual due diligence submissions: Companies will be allowed to submit due diligence statements annually instead of for every shipment or batch placed on the EU market. This change is particularly beneficial for businesses with frequent imports, allowing them to streamline their compliance efforts.
Clarification on ‘ascertaining’ due diligence: The update clarifies the process of ‘ascertaining' that due diligence has been carried out. This allows large companies further down the supply chain to rely on due diligence conducted by upstream suppliers, provided they can verify it was done properly. This reduces the compliance workload for downstream businesses.
Updates to the EUDR FAQ
This is the fourth iteration of the FAQ, with key changes on:
Roles of operators and traders: Clarification regarding the responsibilities of operators and traders (both SMEs and non-SMEs).
Importance of full traceability
Trace products back to the farms and forests where commodities were produced.
Obtain all required geolocation data for these production sites
Assess the complexity of the supply chain and identify risk of circumvention and mixing compliant products with those of unknown origin or non-compliant origin.
Managing composite products: For products made from multiple EUDR commodities, businesses must ensure each component meets due diligence requirements.
Feed for feedstock obligations: Additional information on the obligations for animal feed used in livestock production.
Relevant legislation of the country of production: Clarification regarding ‘country of production’ and ‘relevant legislation’, key concepts for EUDR due diligence.
Scope and due diligence statements: Multiple clarifications on product scope and how to submit due diligence statements help businesses avoid common mistakes.
Information System: New questions have been added to guide companies on using the EU’s Information System.
Changes in the EUDR Guidance
This is the second version of the guidance, with main changes in the sections on packing and packaging materials, waste and recovered and recycled products, composite Products and the role of certifications and third-party verification schemes in risk assessment and risk mitigation. Proposed Amendments in the Draft Delegated Act At the same time, a Delegated Regulation, amending Annex I of the EUDR has been published and is open for public consultation until May 13, 2025. When adopted, it would come into effect the day after its publication in the EU Official Journal. The Delegated Regulation proposes to:
Clarify product scope: By adding ‘ex’ in front of several entries, the amendment specifies that products are only in scope if produced using relevant commodities.
Remove ambiguity on waste and used products: The update clarifies whether waste, second-hand, and used products are covered by the regulation.
Exempt samples and testing products: Products used for examination, analysis, and testing are exempt from due diligence requirements.
Clarify packing materials: The amendment specifies which packing materials and containers are in scope.
Exempt accessory materials: Items like user manuals, leaflets, and marketing materials accompanying products are exempt.
Exclude correspondence: Items of correspondence are explicitly not covered by the regulation.
Next Steps for Businesses
With the EUDR compliance deadline fast approaching, businesses must act now to prepare. While the EU’s Country Risk Classification list is still pending, companies should focus on:
Understand the EUDR and set up a Due Diligence System: Review the updated FAQ and Guidance documents to ensure your due diligence processes align with the latest requirements.
Create awareness with suppliers: Engage suppliers early to ensure they understand their role in providing necessary data and documentation.
Map supply chains for in-scope products: Identify which products are covered by the EUDR and trace their origins to ensure compliance.
Collect required data and documentation: Gather geolocation data, legal compliance evidence, and other necessary information to meet EUDR standards.
QIMA offers expert guidance and solutions to help businesses meet their due diligence obligations efficiently. From supply chain mapping to data collection and risk assessment, our services ensure your company is ready for the EUDR deadline.
For more information on how QIMA can support your EUDR compliance, read more about our EUDR Solutions or contact us at info@qima.com.
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